Evaluation of the Nicaragua Component of the 
USAID/CAM Regional Transparency, Anti￾Corruption and Accountability Program
FINAL REPORT
Prepared by William J. Cartier
Submitted to USAID/Nicaragua
April, 2011
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DISCLAIMER
This assessment report was prepared by William Cartier for review by USAID/Nicaragua. The authors’ views
expressed in this publication do not necessarily reflect the views of the United States Agency for International
Development or the United States Government.   
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Table of Contents
SECTION                 PAGE
List of Acronyms                   3
Executive Summary                   6
Introduction                     8
Section 1: Context, Objectives and Activities                8
Section 2: Main Achievements                18
Section 3: Problems and Issues              22
Section 4: Lessons Learned                38
Section 5: Recommendations              41
Appendix A: List of Interviewees              46
Appendix B: List of Documents and Materials Consulted       50
  
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LIST OF ACRONYMS
AAIN   Nicaraguan Association of Internal Auditors
AJALNIC Nicaraguan Association of Trial Lawyers
AMCHAM American Nicaraguan Chamber of Commerce
BSA   Bureaucratic Simplification Assessment
C&A   Casals and Associates
CAFTA   Central American Free Trade Agreement
CAS‐UCA Center for Social Analysis Central American University
CEAV   Antonio Valdivieso Ecumenical Center
CDM   Municipal Development Committee
CGR   Comptroller General’s Office
CONADER National Commission of Law Faculties
COP   Chief of Party
CORASA Western Radio Corporation, Inc.
CPC   Citizen Power Council
CRR   Radio Romance Corporation
CSE   Supreme Electoral Council
CSO   Civil Society Organization
CTO   Cognizant Technical Officer
CxT   Citizenship for Transparency in Politics
DGCE   General Direction for Government Procurement  
DGI   Tax Administration Office
EVT   Voluntary Transparency Strategy
EyT     Ethics and Transparency Civic Group
FSLN   Sandinista National Liberation Front
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FVBCh   Fundación Violeta Barrios de Chamorro
FUNDEMOS Grupo FUNDEMOS
GON   Government of Nicaragua
GPRE   Electoral Reform Support Group
GS‐CICC   Follow Up Group on the IACC
IACC   Inter‐American Convention against Corruption
IEEPP   Institute of Strategic Studies and Public Policies
IEN   Institute of Nicaraguan Studies
IFES   International Foundation for Electoral Systems
IPADE   Institute for Development and Democracy
JUDENIC   Youth for Nicaraguan Democracy  
LAPOP   Latin American Public Opinion Project
LLR   Lower Level Result
MDC   Municipal Development Committee
M&E   Monitoring and Evaluation
MINSA   Health Ministry
MTI   Ministry of Transportation and Infrastructure
NDI   National democratic Institute
NED   National Endowment for Democracy
NGO   Non‐Governmental Organization
ODC     Office of Public Complaints
OEP   Office of Public Ethics
PGR   Public Prosecutor
PLC   Constitutionalist Liberal Party
PMP   Performance Management Plan
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PROBIDAD Probity Network (Nicaragua)
QPR   Quarterly Performance Report
RFP   Request for Proposal
SCE   Strategic Communications Secretariat
SEJUVE National Youth Secretariat
SubIR   Sub Intermediate Result
STTA   Short Term Technical Assistance
T/AC   Transparency, Anti‐Corruption and Accountability
TO   Task Order
UCA   Central American University
UNCAC   United Nations Convention against Corruption
UNFP   United Nations Food Program
UNO   National Opposition Union
USAID   United States Agency for International Development
USG   United States Government  
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Executive Summary
This document reports on the results of an assessment of the Nicaragua component of the
USAID/CAM Regional Transparency, Anti‐Corruption and Accountability (T/AC) Program, implemented
by Casals & Associates between 2005 and 2009 in Guatemala, El Salvador, Nicaragua and Panama.  The
objectives of the assessment evaluation are to evaluate whether the Nicaragua component of the T/AC
program met its objectives; what have been its impacts; the major problems encountered in T/AC
implementation and the lessons learned and recommendations for future USAID/Nicaragua
programming in this area.
The T/AC program RFP had been designed in 2004 in the context of the negotiation of CAFTA,
and its design was informed by the view that the region had made considerable progress towards stable,
democratic systems of government. Similar to its neighbors, Nicaragua had experienced a successful
transition to democracy, which had allowed for three consecutive periods of democratically elected
government since the 1990 elections. However, as the recent USAID/Nicaragua DG Assessment, carried
out in 2010, contends, more or less at the time that the T/AC RFP was being designed and the Task
Order awarded, Nicaragua was entering an institutional crisis that would reverse many of the gains
made during the democratic transition in the 1990s.  
In the T/AC regional Task Order the overarching objective was “to reduce the level of corruption
that is experienced by citizens”. This objective was expressed in four Sub IRs, as follow: more
transparent systems for management of public resources by the national government; increased
devolution of responsibilities and resources to the local level resulting in greater responsiveness by local
governments; more opportunities for citizen participation in and oversight of national government
decision‐making; and increased accountability of elected and appointed officials. The Sub IRs were
disaggregated into thirteen Lower Level Results (LLRs) understood as distinct program areas. The
Nicaragua component of the program incorporated eleven of these LLRs.  
The assessment concludes that the changed political context of the country had a major impact
on the T/AC program, impeding the program from meeting many of its objectives.  Indeed, in response
to the increasingly adverse political context, the Nicaragua component of the T/AC program suffered a
major modification in 2008, eliminating many of the program areas. However, the assessment also
concludes that the original RFP suffered from serious design flaws, including its overly ambitious scope,
reflected in the large number of LLRs and activities. Even in a more favorable context, the program
would have faced difficulties in meeting its objectives.
The interviewees pointed out that the Nicaragua component of the T/AC program did produce
some important achievements: increased public awareness of corruption issues and policies and the
incorporation of transparency and accountability into the policy agenda; coordinated action by CSOs in
monitoring IACC implementation; the development of approaches and tools for citizen oversight of
government at the national level; legislative approval of the Access to Public Information Law; new
approaches to citizen participation and oversight of local Government and involvement of CSOs in
advocacy for political party and elections reform. Many of these initiatives, supported by USAID, have
continued with funding from other donor agencies.
The achievements listed above were fruit of the support to NGOs working at the national and
local government levels in developing approaches to oversight of government. However, the project
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made no progress towards sustained institutional reforms in the executive branch beyond the Access to
Public Information Law, which it should be noted, has remained essentially a dead letter under the
current FSLN government.  
Among the major program management problems encountered was the shift in the overarching
program objective, from reducing corruption to objectives such as “enhancing capacity” to promote
transparency, a shift that is reflected in the absence of concrete measures of impact in reducing
corruption in public institutions. The major impact indicator discussed in the final report presented by
C&A to USAID was the number of GON officials trained or citizens attending civic education events (see
a full discussion of this point below on page 10). These problems, coupled with the dispersion of T/AC
Nicaragua resources in multiple program areas and activities, meant that during the first three years of
implementation the program was unable to engage the GON in identifying and carrying out specific
reforms.   
USAID/Nicaragua effected a major modification of the T/AC country program in 2008, focusing
efforts exclusively on the local government level, and more specifically on promoting electoral
participation. The assessment concludes that this decision, which was based on short term foreign policy
considerations, was damaging for USAID’s long term efforts to support democratic development in
Nicaragua.  First, because its support for electoral participation was perceived as partisan in its focus by
many of the Nicaraguan observers consulted for this assessment. Without prompting, most of the direct
grantees interviewed declared that the intent of the grants was to forestall a FSLN victory in the
municipal elections.   And second, because it abandoned those activities with NGOs that had shown
some success, i.e., support for the development and application of approaches and tools for oversight of
national government.
With respect to lessons learned and recommendations for future programming, the assessment
concludes that USAID should design RFPs with a tighter focus, fewer activity areas and more
concentration of resources on interventions in targeted public sector institutions. Anti‐corruption
programs need clear commitment from the government, commitments which should be reviewed and
renewed frequently. At the same time, USAID program managers should work with contractors to
develop performance indicators to measure institutional change, using indicators that are useful for
public sector managers in counterpart entities.  
Other recommendations highlight the need to focus on long term objectives in strengthening
democratic institutions and to provide sustained support to build the capacity of NGOs. The assessment
questions the rationale for local level interventions in the area of transparency, recommending that
USAID weight the possibilities for effective programming in circumstances of local elite capture or
absence of political will.   Added to this, in the current political context, national level interventions
represent a better strategic choice.  Finally, we recommend that future anti‐corruption programs not be
regional in scope.
  
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Introduction
The purpose of this evaluation is to evaluate the Nicaragua component of the Central
America/Mexico Transparency and Anti‐Corruption (T/AC) program, implemented by Casals &
Associates during 2006‐2009 in Guatemala, El Salvador, Nicaragua and Panama. The questions
addressed by the evaluation are:
 Did the Nicaragua component of the T/AC program meet its main objectives?
 What have been the lasting impacts of the Nicaragua T/AC program?  
 Was the technical assistance provided adequate to the Nicaraguan context?   
 What were the major problems encountered in the management of the T/AC program?  
 With the benefit of hindsight, is there anything that might have been done better to advance
the program objectives?
 What are the lessons for future USAID Nicaragua programming in this area?
 In the current political environment, how feasible is it to undertake anti‐corruption assistance?
The evaluation is based principally on interviews with stakeholders in Nicaragua during
November‐December, 2010 and review of program reports and deliverables and deliverables of
program grantees. A list of the interviewees is found in Appendix A, below. They include the
USAID/Nicaragua program manager; three of the contractor’s program managers, and most of the major
grantees or sub‐contractors, as well as three senior government counterparts from the Bolaños
government. We did not interview former COPs. The evaluation also takes into consideration T/AC
progress reports, final reports, reports on program indicators and other T/AC technical documents and
documents produced by T/AC partners and grantees.   A list of the documents and other materials
reviewed for the evaluation is in Appendix B.   
The author wishes to thank Jessica Zaman, Luz Marina García, Palak Shah and Mary Ann
Shepherd of USAID Nicaragua for their valuable inputs and assistance in carrying out this assessment
and commenting on the first draft.  Thanks also to the interviewees and especially to the former T/AC
staff for taking the time to share their views and recommendations. Special thanks go to Ondina Olivas
for assistance in the assessment logistics.      
Section 1: Context, Objectives and Activities  
In this section we will look at the project context and objectives, as well as the evolution of the
project activities over time.  Particular emphasis will be on those factors that hindered achievement of
the T/AC project results, including aspects of project decision‐making and management.
1.1 Context
USAID’s programming in the field of transparency and accountability is premised on the
existence of some minimum prerequisites for democratic government.   It is difficult to imagine how
USAID or any other donor agency could effectively support strengthening of transparency and
accountability in government in the absence of relatively free and fair elections, separation of powers,
independence of the judiciary, freedom of the press and the effective right to political organization and
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action. It seems reasonable to expect that when these conditions are not met, or only partially, USAID
programming in the area of transparency and accountability will be less effective.
This is not to say that strengthening of transparency and accountability can only occur in stable
democracies. As a development agency, USAID is often engaged with highly incomplete democracies.
Nevertheless, the decision to support programming in transparency and accountability is a question of
the institutional context. Is there a stable constitutional and legal context to support an anti‐corruption
initiative? Does the political context offer opportunities for progress through new policy initiatives;
legislation in key areas such as freedom of information, conflict of interest, disclosure of assets of public
officials, procurement reform, etc.; and increased political will and independence of judicial and control
institutions in prosecuting corruption cases?
These questions are addressed in the T/AC project RFP and the Task Order. From USAID’s
perspective, there had been considerable progress towards a stable democratic system of government
throughout the region.
USAID assistance to the region over the years has been instrumental in instituting free
and fair elections, a stronger system of checks and balances (including strengthened
audit authorities and ombudsmen), devolution of authority to regional and local levels,
and the rebuilding of a network of private organizations to channel citizen input into
more open, transparent and accessible decision‐making as well as citizen oversight of
public investment.  
The language of the Task Order reflected a consensus that Central America had passed a
threshold with respect to stable democratic institutions. As one early review of democratic development
in Central America has noted, for many observers by the mid‐1980s there had occurred a remarkable
“outbreak” of elected governments—with the inauguration of President Cerezo Arévalo in Guatemala
for the first time in memory all five of the countries in the region had democratically elected
governments.1 Since then the institutionalization of democratic systems of government continued
apace—as epitomized by the Nicaraguan elections of 1990 which saw the peaceful transfer of power
between the FSLN and the UNO government under Violeta Barrios Chamorro.
With the 1990 elections Nicaragua began an unprecedented period of four consecutive periods
of democratically elected government, a negotiated end to the civil war, and the demobilization of
irregular forces, followed by a 1995 Constitutional Reform that reinforced liberal democratic principles,
strengthened the separation of powers and judicial independence; submitted the Army and Police to
civilian control, and increased the autonomy of sub‐national governments. At the same time, Nicaragua
experienced a substantial increase in press freedoms and respect for freedom of organization and
assembly, evidenced by a growing number of CSOs. However, as the recent USAID/Nicaragua DG
Assessment contends, more or less at the time that the T/AC RFP was being designed and the Task
Order awarded, Nicaragua was entering an institutional crisis that would reverse many of the gains
made during the democratic transition in the 1990s.  
                                                            
1 See J. A. Booth 1989. “Elections and Democracy in Central America: A Framework for Analysis”. In J. Booth and M.
Seligson (ed.) Elections and Democracy in Central America, Vol. 8.   Chapel Hill: The University of North Carolina
Press.  
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The crisis was the result of a decision in 1999‐2000 by elites within the two main political parties
(PLC and FSLN) to enter into a “pact” to divide up control of the Supreme Court, Supreme Electoral
Council (CSE), Attorney General, Public Prosecutor (PGR), and Comptroller (CGR). As well as ensuring the
political and over time the pact was extended to cooperation between the FSLN and PLC on legislative
initiatives. The perverse impact of the PLC‐FSLN pact on democratic institutions became apparent in the
Bolaños government (2002‐2007), as a result of the investigation, prosecution and sentencing of ex‐
president Arnoldo Aleman on corruption charges.  
In response, the PLC and FSLN agreed on a constitutional reform taking away executive powers
in key policy areas and at the same time initiating an impeachment process against Bolaños. The
President refused to recognize the reforms; and it took a ruling by the Central American Court of Justice
and constant mediation by the OAS over the course of several months to bring the country back to a
constitutional government. As the conflict between Bolaños and Aleman heated up in 2003, the
“arnoldista” faction of the PLC made common cause with the FSLN and blocked many of the incumbent
government’s legislative initiatives.  
For much of the period, the Bolaños government was limited to making policy within the
executive branch. As one trenchant observer put it, the main opposition party during the Bolaños
government was in fact the PLC! But there were important exceptions, including the passage of
legislation approving CAFTA and a Public Participation Law. In the field of transparency and anti‐
corruption reforms, too, the Bolaños government initially showed progress, not only in the decision to
investigate and prosecute ex‐president Arnoldo Aleman, but also in promoting policy reforms. The
Bolaños government signed the United Nations Convention against Corruption (UNCAC) in 2003 and
ratified it in 2006. It also took steps to bring into force the Inter‐American Convention against
Corruption (IACC) by designating a “central authority” responsible for coordinating policies to
implement the provisions of the IACC.  
The entity responsible for IACC implementation was the newly created Office of Public Ethics
(OPE) in the Presidency. The OPE, along with the Secretary of Strategic Communications (SSC) also in the
Presidency, attempted to develop a national anti‐corruption policy. Many of the proposed actions built
on the experience of the National Integrity Committee (NIC) created in 1999 during the Aleman
government. However, most of the important policy proposals, including the Access to Public
Information Law, suffered significant setbacks and delays, as the Bolaños government dedicated
increasing energies to fending off attacks by the FSLN and PLC.  
Thus, for the USAID‐Nicaragua T/AC program, just beginning activities in 2005, this situation was
hardly propitious for a major anti‐corruption initiative in partnership with the GON. Outside of the
executive branch, the main control agencies—CNG and PNG—and the judiciary were firmly under the
control of the PLC‐FSLN pact. As a result of these and other factors, the T/AC program made little
headway in the first year in developing strategies with government; and as we will describe in detail
below, from the beginning of the project most efforts would go towards supporting civil society
initiatives.
More importantly, for the T/AC program, the power sharing agreement led to the division of the
center‐right electorate between the PLC and the NLA and an eventual Sandinista victory in the 2006
national elections. Since then, FSLN/PLC control over the other state institutions has worked to
undermine the separation of powers and the independence of the CSJ and the lower judiciary, the CSE,
and the AG, as well as immobilizing the offices of the Public Prosecutor and Comptroller. This process
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culminated in an electoral fraud perpetrated by the CSE during the 2008 municipal elections. In other
words, just at the moment in which the T/AC project was staring up, Nicaragua was experiencing a
precipitous deterioration of its democratic institutions.
Once in power, the FSLN government also took a series of measures aimed at limiting the
activities of civil society organizations (CSOs). One key measure was the establishment of Popular Power
Councils (CPCs) as the preferred channel for popular participation. Other kinds of CSOs, independent of
FSLN control, were marginalized and excluded from decision‐making. Over time, the government began
to take more aggressive measures, harassing CSOs and independent media organizations.  Similarly, the
government began to exert pressure on donor agencies to reduce their support to NGOs deemed to be
hostile to Sandinista interests. One telling example was the decision of the Multi‐Donor Anticorruption
Fund in 2009 to bow to government pressure to suspend support to CSOs working in transparency and
anti‐corruption activities
The increasingly authoritarian tendencies came to a head during the 2008 municipal elections, in
which the CSE orchestrated an electoral fraud denying the PLC victory in some forty municipalities,
including most of the departmental capitals. The fraud was well planned, involving manipulation of the
voter registry through political control over issuance of identity cards, refusal or delays in recognizing
opposition parties, refusal to allow independent election observers to work unhindered, harassment of
NGOs and media outlets, and finally, falsification of the results in individual polling stations. Subsequent
to the municipal elections and the change from PLC to FSLN local governments, the Sandinistas moved
to close off spaces for democratic deliberation at the local level, reinforcing the CPCs, and marginalizing
the Municipal Development Committees (MDCs) established by the Citizen Participation Law passed
under the Bolaños government.    
1.2 T/AC Objectives
Set against this increasingly adverse institutional context, in retrospect the objectives of the
T/AC Task Order seem challenging indeed. The Task Order recognized that in the course of the transition
to stable, democratic systems of government in Central America, one of the critical emerging problems
was corruption, which in addition to siphoning off scarce public resources from policy areas such as
health, education and infrastructure, is seen to have a corrosive impact on citizen support for
democracy.2
   
This Anti‐corruption, Transparency & Accountability Program seeks to help the region‘s new
system of democratic governance increase equitable access to public resources and services,
thereby strengthening the legitimacy and commitment to democracy on the part of the public at
large. Controlling corruption is a task of generations…. The key challenge for the Contractor will
be to assist the Government in each participating country, the private sector, civil society and
other key actors to work together to slow and begin to reverse the significant expansion of
corruption that has occurred over the recent past, improve transparency, and project to the
public credible and effective stewardship of the country and of public resources.
                                                            
2 This general argument is supported by comparative empirical research on democratic values, carried out by the
Latin American Public Opinion Project (LAPOP).  According to LAPOP studies of Nicaragua in 2004, 2006, 2008 and
2010, people who experience corruption tend to show lower levels of support for democratic government.  
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In the Task Order the overarching objective was “to reduce the level of corruption that is
experienced by citizens…as well as to increase the level of transparency and government
accountability”.3 Following the CAM results framework, this objective was expressed in four, specific Sub
IRs, as follows:  
 Sub IR 2.1: More transparent systems for management of public resources by the
national government
 Sub IR 2.2: Increased devolution of responsibilities and resources to the local level
resulting in greater responsiveness by local governments to citizen needs
 Sub IR 2.3: More opportunities for citizen participation in and oversight of national
government decision‐making
 SUB IR 2.4: Accountability of elected and appointed officials improved
The relative importance of these results varied across each of the participating countries,
however, all four of the participating countries carried out activities in all of the Sub IRs, and usually in
all or most of the respective LLRs.   In other words, the objectives of the T/AC program were very
ambitious indeed, in that they touched on multiple areas of public policy reform across a range of
executive, justice and control agencies, as well as involving local governments, civil society, media and
private sector organizations. This will be discussed in detail below.  
1.3 T/AC Program Activities
  
The major changes in the T/AC Nicaragua program activities between the first phase of the
program (2005‐2007) and the second phase (2008‐2009) are summarized in the following table. The first
phase corresponds to the last two years of the Bolaños government and the first year of the Ortega
government, during which the program continued to attempt to work with national government
institutions in designing and implementing transparency and anti‐corruption reforms. The second phase
represents a major shift in programmatic emphasis, reflecting the belief that there was insufficient
political will at the national level to carry out transparency reforms.    
1.3.1 Phase 1: 2005‐2007
  
In this first phase (2005‐2007), the program activities encompassed eleven of the thirteen
original LLRs set out in the multi‐country Task Order.  In this sense, in its initial phase at least, it had a
very wide‐ranging set of objectives and activities.  
With respect to the program activities during this first phase of T/AC Nicaragua, as we will
discuss in greater detail in the following section, in Year 1 the program made little progress towards
expected results.  In addition to long delays in program start‐up and mobilization of key personnel and
local staff, subsequent to start‐up much time was lost in trying to reach agreements with potential
counterparts in the office of the Presidency (Secretary for Strategic Communications‐SCE and the Office
of Public Ethics‐OEP) on joint activities.4
  
                                                            
3 See the TAC Task Order, page 3, Section A.3: “The purpose of the work to be carried out under this Task Order is
to reduce the level of corruption that is experienced by citizens in the participating countries, which diverts
resources from intended uses or subverts decision‐making processes to benefit a few at the expense of the public
good, as well as to increase the level of transparency and government accountability”.
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The major program activities undertaken during the 3rd and 4th Quarters of Year 1 were the
awarding of grants to EYT to carry out social auditing of municipal budgets in five municipalities and to
Grupo Fundemos for participatory budgeting in three municipalities; the commitment of T/AC support
for a CSO alliance to monitor IACC compliance; and an agreement with IFES to initiate a series of
activities on political party financing. However, the initiation of the Fundemos grant activities was
delayed for several months, owing in part to lack of approval of municipal selection and to problems in
reporting.
Table 1:  Summary of T/AC Nicaragua activities under IRs and LLRs
Results Statements T/AC Nicaragua
2005‐07   2008‐09
Sub IR 2.1: More transparent systems for management of public resources by the national government
LLR 2.1.1: National anti‐corruption/transparency strategy completed and implemented √   
LLR 2.1.2: Implementation of Inter‐American Convention against Corruption Commitments √  √ 
LLR 2.1.3: Improved national government budget transparency, management and execution √   
LLR 2.1.4: Systemic government deficiencies identified and addressed in key line ministries   
LLR 2.1.5: Initiatives to reduce petty corruption (bribe solicitation) developed and implemented √   
LLR 2.1.6: Key oversight agencies strengthened √   
Sub IR 2.2: Increased devolution of responsibilities and resources to the local level resulting in greater
responsiveness by local governments to citizen needs
LLR 2.2.1: Improved decentralization policy framework   
LLR 2.2.2: Improved local government budget transparency, management and execution √   
Sub IR 2.3: More opportunities for citizen participation in and oversight of national government decision‐
making
LLR 2.3.1: Strong civil society participation and oversight √  √ 
LLR 2.3.2: Clear leadership role and ethical standards for the private sector √   
LLR 2.3.3: Capacity of the media to report on transparency and corruption issues increased √  √ 
SUB IR 2.4: Accountability of elected and appointed officials approved
LLR 2.4.1: Political Parties and elected leaders accountability improved √  √ 
LLR 2.4.2: Improved government ethics and disclosure of assets of public officials and candidates
for public office √ 
After this slow start, in Year 2, with a change in the Nicaragua program Director, implementation
of T/AC program activities picked up considerably both with the GON and civil society actors.  With the
GON, the main program activities were as follows:
 The program supported an ongoing dialogue between the OEP and the “Follow‐up Group” of 14
CSOs on the implementation of the IACC, while providing training to both government officials
and CSO representatives on the convention.5
  
                                                                                                                                                                                               
4 For example, in QPRs 4 and 5, there were still constant references to “exploratory” conversations with GON and
CSOs to agree on the design of strategies and joint activities.
5 The members of the IACC follow‐up group in 2006‐2007 were AAIN, ADHML, AJALNIC, AMCHAM, CAS‐UCA, CEAV,
CONADER, FVBCh, EyT, FUNDEMOS, Hagamos Democracia, IEN, Movimiento Poder Ciudadano, and Red
Probidad/Nicaragua.
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 T/AC also worked with the OEP to support a pilot project to improve access to information in
eight GON agencies at the national level and to coordinate the implementation of a Bureaucratic
Simplification Assessment (BSA) with two agencies.  
 Also, the program supported the Secretary of Strategic Communications (SCE) of the Presidency,
to carry out a public awareness campaign on corruption.   
 In coordination with the USAID/Rule of Law Program, T/AC Nicaragua supported a public
awareness campaign in pro of the Office of Citizen Complaints (ODC) of the PGR, disseminating
information about the role and functions of the ODC.  
 In conjunction with UNICEF and UNFP, the program supported the National Youth Secretariat
(SEJUVE) to carry out a survey of young people’s perceptions and opinions in areas such as
democratic culture, elections, and social policies.
 At the end of Year2, T/AC initiated a pilot project with the DGE to strengthen procurement
management in the 20 targeted municipalities, and began work in 5 municipalities.   
Most of the initiatives with the GON in Year 2 were fraught with problems and delays.  The SCE
and OEP, as the program’s main counterparts, carried little political weight with line ministries and
agencies. This problem, coupled with the impending 2006 national elections, made it increasingly
difficult to make progress with the SCE, OEP, CDP and other GON agencies in designing and
implementing anti‐corruption strategies. There was no progress at all in designing institutional strategies
for addressing petty corruption.   
In comparison to the slow and uneven progress in activities with its GON counterparts, in Year 2
the Nicaragua T/AC program was much more successful in implementing activities with CSOs, at first
through jointly funded activities and later through a series of sub‐grants. Following on the grants
awarded to EyT and Fundemos at the end of Year 1, the T/AC program in Year 2 signed a series of grant
agreements and sub‐contracts with other CSOs different areas. The most important grants and sub‐
contracts during the first phase of T/AC Nicaragua are as follows:6
 IEEPP to develop and apply social auditing methods to the national and local government
budget process.
 Red Local Para el Desarrollo, to develop approaches for and promoting transparency and citizen
participation in decision‐making in five municipalities.
 FVBCh, to promote and advocate passage of access to information legislation by the National
Assembly.
 Hagamos Democracia, to carry out oversight of the legislative process and budget management
in the National Assembly.
 JUDENIC to conduct a social auditing exercise on the way in which public resources are assigned
to public universities and how they are spent.
 CEAV to conduct a social audit of the Managua city government focusing on management and
organization of municipal markets; management of urban public transportation, and
procurement.  
                                                                                                                                                                                               
6 During the 3rd and 4th Quarters of Year 2, subsequent to the arrival of the new COP, T/AC Nicaragua signed 14
grant agreements with CSOs totaling about US$700,000.  
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 Universidad Centro Americana (UCA) to conduct a survey of democratic culture using an over
sample of the 20 T/AC municipalities, applying the instrument developed for the LAPOP survey
conducted by Vanderbilt University.
In addition to these grants and contracts, T/AC provided a grant to IFES to provide technical
leadership and assistance to the Citizenship for Transparency in Politics coalition to raise public
awareness on issues of party financing during the upcoming national elections. As part of this “Strategic
Small Grant Package Initiative on Political Party Finance”, T/AC Nicaragua approved sub‐grants to five of
the member CSOs in the run up to the 2006 elections: Hagamos Democracia, Fundemos, IPADE, EYT, and
FVBCh.
In Year 3, the changed political context in 2007 caused severe difficulties in program
implementation. For example, it was impossible to get formal GON approval to participate in the
assessment of compliance with IACC provisions. The Bureaucratic Simplification Assessments in the DGI
and MINSA ran into increasing resistance. Similarly, at the local level, the program was obliged to
substitute some of the original participating municipalities, owing to the reduced commitment from the
incumbent FSLN mayors. All of the T/AC grantees working in social auditing at the national and local
levels found it increasingly difficult to access information on planning, budgeting, service provision,
procurement, etc.   
In the face of these growing difficulties with the GON, the T/AC program launched several
important new activities with CSOs in Year 3, including the following activities:
 Approval of a package of six small grants to members of the “IACC CSO follow‐up group”,
including a grant to AAIN to carry out a mapping of IACC compliance in different GON agencies,
and grants to other CSOs to support training on IACC provisions and compliance at the local
level.7
  
 A grant to IEEPP for a “transparency observatory” for the military and security sectors, involving
oversight of budgets and procurement, transparency issues and a national survey on citizen
security.  
 A first ever national survey to measure the cost of bureaucratic corruption, designed by an
international consultant and conducted by CID‐Gallup.
 A high profile series of “transparency forums”. The second forum was on investigation of
corruption cases and involved officials from the CGR and PGR as well as civil society
representatives.
1.3.2 Phase 2: 2008‐2009
By the middle of Year 3 the Nicaragua T/AC program activities focused almost exclusively on
work with CSOs, independent media organizations and political parties. With time, the program had lost
contact with the GON except for occasional discussions with the National Assembly on the Legislative
Barometer and with the PGR on issues of IACC implementation and monitoring. This movement towards
an exclusively CSO focus in the Nicaragua component of the T/AC program was formalized by a contract
modification approved in May, 2008, after which and for the remainder of the program (Years 4 and 5)
                                                            
7 The six grants for monitoring IACC compliance in 2007 totaled about $500,000 dollars, divided among six
organizations.  The largest single grant was to AAIN.  
16
restricted activities to only four of the original thirteen LLRs (see the summary of Sub IRs and LLRs in
Table 1 above).  
It should be emphasized that this decision to refocus the T/AC program was in the context of
growing authoritarian tendencies within the FSLN government and high levels of political interference in
the justice sector—as discussed in the recent Nicaragua DG Assessment. At the time there was also a
legal prohibition on providing USAID funded assistance to the judicial sector, except for the Office of the
Public Defender, the Forensics Office and local level judges.   
Another important thrust of the 2008 contract modification was the increased emphasis on
small grants to CSOs and media organizations. The original Task Order included a “sub‐award program to
fund CSO programs that support the achievement of USAID Program results”.  With Modification 29, this
was expanded considerably in both scope and funding under the rubric of a “Civil Society Grant Fund
Program” within LLR 2.3.1, “to support specific anti‐corruption and social auditing activities within the
context of the upcoming municipal electoral process”. During 2008 and 2009, for all intents and
purposes T/AC Nicaragua was focused on the small grants program.
In the first round of the new grants program, the T/AC program funded fifteen initiatives by
national and regional NGOs and media organizations, for a total of about $320 thousand dollars, that is,
approximately $20 thousand dollars per grant on average. The first round of small grants was formally
approved in March, 2008. The second round, approved in September, 2008 barely two months before
the municipal elections, funded 20 small grants, again to NGOs and media organizations, for a total of
$586 thousand dollars, on average $29 thousand per grant.  
The grants had a mainly local emphasis, with each grantee focusing activities on a sub‐set of 33
local governments in the first round and 38 in the second round of awards.  The geographic focus of
each grant was negotiated with C&A.   Several of the media grants had a broader regional and even
national scope. The thematic focus of the grants included: public debate through the creation of local
“citizen agendas” involving women, ethnic groups and youth; promotion of participation in electoral
campaigns and voting, especially youth voting; support to potential voters to do an on‐line verification
of the voter registry; and awareness‐raising and oversight of transparency issues in municipal electoral
campaigns. About 12,300 youth, women and community activists received training in different aspects
of democratic governance, constitutional and legal aspects of elections and voting, and transparency
and oversight. Another five thousand people participated in local fora on elections issues in the targeted
municipalities.
One of the highest profile grants, given its geographic focus on Managua and Leon, was the
grant to JUDENIC to promote electoral participation among young people—especially first time voters.
The grant supported the production and broadcast of a campaign of short “spots” on television and
radio and in movie theatres in Managua, accompanied by distribution of printed materials in universities
in Managua and Leon.  The report presented by C&A refers to an audience of 141,909 young people
between 18 and 24 years of age, the majority of them in Managua. Without attributing impact, the
project narrative refers to the fact that in 2008 there were 96,000 first time voters.  
The media grants also included a grant to CORASA (Corporacion de Radios de Occidente S.A.) to
carry out civic education and promote electoral participation. The grant covered not just radio programs
themselves, but also the organization of local fora with CSOs and political parties, which were broadcast
on the radio in the departments of Leon and Chinandega.  Another media grant went to Corporacion
17
Radio Romance (CRR), to write, produce and broadcast a radio “mini‐series”, titled “Momentos”, several
programs dedicated to political analysis and debate, and a series of short “spots” to promote electoral
participation. They were aired by Stereo Romance (Carazo), Radio XO (Rivas), Radio Bésame (Masaya‐
Granada) and Radio Eco Stéreo (Carazo). The impact of these two grants was described in terms of the
increase in voter turn‐out, 12,601 additional voters in the case of the grant to CORASA and 2,752
additional voters in the case of CRR.  
In the assessment interviews, several of the grantees complained that they were obliged by C&A
to focus on municipalities in which they had no prior experience, and were much less effective than they
could have been.8 For this reason, among others, many of the T/AC grantees perceived the contractual
relationship with C&A as more of a service contract than a grant per se.  Several mentioned that they
were required to give verbal or written summaries of grant activities on a weekly basis for C&A and
USAID, reflecting in their view, the heightened political sensitivity of their grant activities in the run up
to the elections.   
Most of the direct grantees interviewed also highlighted the “political reading” of the T/AC small
grants program, which according to them was seen by all political observers, whether in government or
opposition, as a means of supporting the opposition to the FSLN in the municipal elections. This reading
of the political‐partisan nature of the small grants program was given without prompting by the
interviewer.9 While USAID/Nicaragua was clear in instructing grantees not to take a partisan political
stance, in fact, many of the grantees did just that, favoring the opposition to the FSLN.  Although a few
of the grantees were seen to be overtly partisan in their field activities, the bias was more usually felt in
the choice of the grantees themselves, and the terms of the debates and events, in a contrast between a
“democratic” option represented by the Liberal party candidates and the “non‐democratic” option of
the FSLN.   
In the wake of the FSLN victory in the municipal elections and the accusations of widespread
electoral fraud, for the remainder of the T/AC program period, the emphasis was on strengthening
citizen participation at the local level. Working through the CDMs, T/AC promoted the adoption of
municipal bylaws to implement the Citizen Participation Law, and training leaders and activists on its
use.  This activity took place in the context of increasing political polarization and the decision by most
of the newly elected FSLN Mayors to marginalize the CDMs, in favor of the newly established CPCs,
which limited the effectiveness of the T/AC supported activities in supporting citizen participation in
local government through the CDM mechanism.   
Overall, it is fair to say that from about mid‐2007 and formally after the 2008 contract
modification, T/AC Nicaragua was no longer focused on transparency and anti‐corruption issues at the
national level, but rather evolved into a citizen participation program using small grants to NGOs,
focusing first on participation in local elections, and subsequently on participation in local decision‐
making. As the T/AC Nicaragua final report puts it:
                                                            
8
  I.e., when two NGOs proposed to work in the same municipalities, in several instances C&A requested one of the
NGOs to resubmit with a different set of municipalities.
9 Eleven of the T/AC program grantees interviewed for the assessment considered that the small grants program
was partisan in its orientation, although they all recognized that USAID gave instructions to the contrary.  
18
After the 2006 national elections, it became difficult to collaborate with the GON. The new
Administration’s agenda was more oriented towards implementing poverty reduction programs
for example than on focusing on anti‐corruption matters, which curtailed collaboration between
the Program and the GON significantly…. Under this scenario, the Program shifted focus from
the national level to the local level in an attempt to work with municipal governments and their
constituents. Interest in pursuing anti‐corruption, transparency, and citizen participation efforts
were visibly higher at the local level. Additionally, the Program focused on providing voter
education as the 2008 municipal elections were fast approaching and support in this area was
deemed to be of the utmost importance.10
Section 2: Main Achievements  
Before addressing the obstacles and problems in T/AC implementation it is worthwhile to look
at some of its main achievements as seen by the main program partners and grantees, and by
USAID/Nicaragua program managers. These achievements are: heightened awareness of corruption
issues and policies; increased CSO cooperation in monitoring and pressure for IACC compliance; new
approaches and initiatives for CSO budget oversight at the national level; passage of the access to
information law; new approaches to citizen participation and oversight of local governments; and
proposals for political party and electoral reforms. Each of these achievements is described briefly
below.  
2.1 Awareness of corruption issues and policies
Many of the T/AC partners interviewed in the course of the present evaluation emphasize the
contribution of the program in putting transparency and corruption issues on the national policy agenda
and introducing new concepts of transparency and accountability in politics. While recognizing the
obstacles to effective policy responses in the Bolaños and Ortega governments, most consider that there
is now a better understanding of corruption among specialized audiences (researchers, academics,
policy makers, CSO activists and political party leaders) as an issue and greater awareness of the need
for anti‐corruption strategies and policies.
More generally, the program partners and grantees argue that T/AC was instrumental in putting
anti‐corruption issues on the national agenda, and identifying specific policies for addressing public
sector corruption. The increased awareness and understanding of corruption issues was achieved
through training, public conferences, electoral fora and other events, and media activities.  With respect
to training activities, the program provided training for a very large pool of elected officials, political
party leaders and members, senior non‐elected national government officials, journalists, academics,
local government politicians, NGO leaders and program managers, CSO activists at the national level,
and community leaders at the local level. Overall, the T/AC Nicaragua component trained over 20,000
people in corruption issues and anti‐corruption policies, mainly in the Years 1, 2 and 3 of the program.11  
                                                            
10 See the summary of achievements in CAM Anti‐Corruption, transparency and Accountability Program Final
Report. Nicaragua. July 30, 2009.
11   See also the summary of training in CAM Anti‐Corruption, transparency and Accountability Program Final
Report. Nicaragua. July 30, 2009, pages 40‐48.
19
About another 17,000 people attended diverse civic education events, most of them at the local level,
and mainly in Year 4 of the program.
The results are mainly in the civil society sphere, in which the work of NGOs is widely reported
by the print and electronic media, which creates pressure on the government on issues of transparency
and corruption.12  But this constant pressure has obliged even the FSLN to respond. While the current
government has usually attacked NGOs that publish reports on corruption, it has incorporated a few of
the specific policy interventions, notably in the area of combating petty corruption in health and
education service provision.13   Another example is the recent initiative by the Federation of Justice
Sector Workers, a FSLN affiliated union, to combat petty corruption in the courts.14 In this sense, it is
clear that the T/AC program has been fundamental in framing a new agenda of public policy debate, in
which even the most recalcitrant government is obliged to take action.  
2.2 CSO cooperation in monitoring IACC implementation  
The T/AC program provided international STTA for training and technical assistance for a
coalition of Nicaraguan CSOs in understanding the legal provisions and mechanisms for IACC
implementation and supported the wok of the CSOs in carrying out monitoring of compliance. There is
now a greater awareness and understanding among civil society leaders and activists about IACC.  This
effort has continued after the end of the T/AC program, led by EyT, which has presented two CSO
monitoring reports in the framework of the IACC, with the cooperation of other CSOs. The most recent
report for 2010 was produced by EyT in cooperation with UCA, IEEPP, AJALNIC, and the Fundacion
Monsenor Lezcano.  
This is an important gain, in part because the Nicaraguan government continues to be sensitive
to international opinion. The responsibility for IACC compliance is now in the office of the PGR, which
because of the continued pressure from NGOs has been forced to exercise greater diligence in the IACC
process. This is without a doubt the major substantive achievement of the program. The most recent
IACC monitoring report, cited above, while recognizing advances in legislation in areas such as access to
public information (Law 621); strengthened external control exercised by the CRG (Law 681), and an
improved civil service career (Law 438), also observes that owing to the politicized and corrupt judicial
system, these laws continue to be a dead letter.15  Using this report, EyT has continued to exert pressure
on the GON for implementation of these and other laws.16
                                                                                                                                                                                               
12 See the article, “Nicaragua retrocede por la corrupción” in La Prensa on July 30, 2009, reporting o the results of a
regional study on corruption.(http://archivo.laprensa.com.ni/archivo/2009/julio/30/noticias/politica/340936.
shtml)  
14 See the article in Voz del Sandinismo. (http://www.lavozdelsandinismo.com/nicaragua/2011‐04‐07/impulsan‐
campana‐contra‐la corrupcion/)
15 EyT. 2010. Informe de respuestas de la Sociedad Civil de Nicaragua al cuestionario de la 3ra. Ronda de
evaluación. (http://www.eyt.org.ni/media/osc3.pdf)
16 EyT’s reports are regularly covered in the print and electronic media. See the article in Nuevo Diario on the
second round of monitoring of the IAAC:  (http://www.elnuevodiario.com.ni/politica/9186)
20
2.3 Methodologies for citizen oversight at the national level  
The T/AC program in Nicaragua supported the research institute, IEEPP, in carrying out oversight
of the national budget in key areas, including defense, security and social policy (health and education).  
IEEPP developed a team of researchers and analysts specialized in budget analysis. Over the course of
the program, and with USAID funding, IEEPP positioned itself as the national partner for the
International Budget Project.  IEEPP is now an obligatory reference point for other CSOs, journalists and
even political parties and Deputies in the National Assembly, who frequently refer to IEEPPs analysis and
reports.  
Owing in part to T/AC program support, IEEPP has been able to access additional funding from
other agencies such as NED to continue to develop expertise and human capacity in this area. In the
most recent national government budget process, IEEPP has published and disseminated a series of
analyses, on the implementation of the current medium term budget framework for 2006‐2014 and the
use of the resources from the HIPC debt relief mechanism, and tendencies in social spending in the
context of the economic recovery and the upcoming 2011 elections, with particular emphasis on the
financing and use of the “bono solidario”, “bono productivo”, “usura cero” and other direct government
subsidies.17
Similarly, with the support of the T/AC program, Hagamos Democracia developed an approach
for carrying out oversight of the National Assembly and disseminating results through a “Legislative
Barometer”. This effort was maintained up to late 2010 in electronic form with support from other
donors, including the EU and NED. By the time it was closed, it had had accumulated over 100,000 hits,
an impressive readership in the Nicaraguan context and a good indicator of its unique role in legislative
oversight.18
2.4 Access to Public Information Law   
During the first two years of the program, T/AC Nicaragua maintained support for a group of
CSOs to advocate for passage of a law guaranteeing access to public information, led by the FBVCh but
supported by other NGOs and media organizations. As in the case of transparency and accountability
issues more generally, the T/AC program contributed to making access to information part of the
political lexicon. The law was eventually approved by the National Assembly during the first legislature
of the newly elected FSLN government in 2007.
While the incumbent government has blocked effective implementation of the law, CSOs and
media organizations continue to use it as a point of reference. It is hoped that in the event of a more
open government, the implementation of the law will become a rallying point and focus of NGO and
CSO advocacy.  The FVBCh, in particular, has remained very active in promoting the implementation of
the reform (Law 621).  With support from the EU, it is promoting the use of the law by CSOs, including
the CPCs, at the local level.  While the recent activity reports on the FVBCh project are not heartening—
                                                            
17   IEEPP. 2011a. Marco presupuestario de mediano plazo en Nicaragua 2006‐2014. Managua: IEEP; and IEEP.
2011b. PGR 2011 El gasto social en el contexto electoral y de recuperación económica.  Managua: IEEP. These can
be downloaded at: http://www.ieepp.org/
18 See Barometro Legislativo, August 2010,   (http://hagamosdemocracia.org.ni/index.php?option=com content
&view=article&id=59:barometro‐legislativo‐diario‐25‐de‐agosto‐de‐2010&catid=14:legislativo)
21
FSLN officials in Managua are unwilling to even discuss the provisions of the law—some members of the
CPCs who participated in the program show interest in using it to improve their understanding of
municipal policies and programs.19   
2.5 Approaches to Citizen Participation and Oversight of Local Government   
In the early stages of the T/AC program, and again in the final year, there was substantial
progress made on developing and testing new approaches and tools for promoting civil society
participation in planning and budgeting, and in carrying out social auditing of local government
programs and projects. These methodologies, developed by Fundemos, EyT and Red Local,   have
continued to be used (or adapted) today by several national and regional level NGOs who will be
working with USAID/Nicaragua’s municipal governance project, which began activities at time of writing
of this report.
These NGOs attempted to put into practice various legal provisions in the Citizen Participation
Law and the Municipal Law, which allow for citizen participation in planning, budgeting and other
policies. The implementing regulations of the Citizen Participation Law provide for the establishment of
Municipal Development Committees (CDM) in all local governments.  Under the current government, in
most FSLN municipalities the CDMs have been sidelined, however they continue to be a reference point
for civic action and mobilization in many localities, even in the face of the growing power of the CPCs.  In
some cases CPCs are members of CDMs. Thus, despite the adverse political environment, the
mechanism of the CDM is still relevant. In addition, the program was able to promote the passage of
model “citizen participation ordinances” in four participating municipalities in the last year of the
program.  
More importantly, the activities of the T/AC program have generated a set of approaches and
tools for citizen participation and oversight at the local level. NGOs such as Fundemos, EyT, Hagamos
Democracia, IPADE, Red Local, and FVBCh have designed their own training materials.  And according to
information provided by the COTR and the COP, USAID/Nicaragua’s municipal governance program will
build on these methods and tools. A first workshop with NGOs was held in November, 2010 to review
NGO experience in citizen participation and social auditing, including several of the approaches
developed by T/AC program’s grantees.  
2.6 Proposals for Political Party and Elections Reform
The T/AC program contributed to building technical expertise in issues of political party and
electoral reforms, contributing to the establishment of the Citizen Network for Transparency in Politics,
made up of eight NGOs.  The initiative came out of the Political Party Finance activities carried out under
the leadership of IFES and a set of five sub‐grantees: Hagamos Democracia, Fundemos, IPADE, EYT, and
FVBCh.  The initiative included a common website, Citizens for Transparency (www.cxtp.org.ni) and a
series of research projects, publications, public events and fora, and media outreach.  It supported two
national fora on political party finance, which presented and debated proposals on reforms of political
party financing, a topic which received significant press coverage throughout 2007 and 2008. The
national level activities were suspended in 2008 with the shift in the T/AC program to focus on issues
                                                             19 FVBCh. 2010. La Participación Ciudadana y el Acceso a la Información Pública.  Diagnóstico en el Municipio de
Managua. (http://www.violetachamorro.org.ni/images/presentacion_managua_martes1249_pm_uv.pdf)
22
related to the municipal elections. However, it is worth mentioning that these local level activities built
on the activities at the national level, including campaigns and public events to debate issues of political
party financing.    
Despite the adverse political context, since the end of the T/AC program funding, this initiative
was able to consolidate and expand, in the form of the “Electoral Reform Group”, now under the
auspices of IPADE, with 16 member organizations.20 Again, it encompasses policy research, advocacy,
public events, and media outreach.  It has put forward a series of recommendations for reforms in the
run up to the 2011 national elections, focusing on reform of the CSE. Its various member organizations
have received funding from other donor agencies for policy research, debate and advocacy in this same
area.21 The work of the GPRE receives considerable press coverage in daily newspapers on issues such as
political party financing and reforms to the electoral law and the CSE.22 Individual members of the GPRE
also carry out activities within the framework of the group; for example, the “Forum on Political Parties
in Nicaragua” organized in October 2010 by “Hagamos Democracia” with the Universidad Americana
(UAM).
Section 3: Problems and Issues
In this section the assessment looks at the principle problems encountered both in program
design, planning and management. Before detailing these problems and issues, we recognize the
challenging political context, in particular the change in government and the increasingly “illiberal”
nature of the FSLN, reflected in harassment and intimidation directed towards civil society and
communications media; increased government secrecy and reduced access to information; attempts to
establish a monopoly on citizen participation through the CPC mechanism; increased interference in
justice and control institutions; and violation of constitutional and legal provisions guaranteeing free and
fair elections.  
Even so, we consider that the T/AC program suffered from serious design problems of its own
making. The problems in program design have much to do with USAID’s overall approach to anti‐
corruption work, based on the “principal‐agent” theory put forward in the 1980s by economists and
“institutionalist” political scientists.23  For reasons unknown, this comprehensive or “holistic” approach
often takes the form of multiple, simultaneous interventions across branches of government, at national
and sub‐national levels. Numerous recent studies and program evaluations have questioned the efficacy
and sustainability of this approach to anti‐corruption policies. These problems will be discussed in detail
below.  
                                                             20  See the description of the Electoral Reform Group members, activities, publications and events on the IPADE
website: http://www.ipade.org.ni/grupopropuesta.html
21 IPADE/GPRE. 2010. Propuesta desde la Sociedad Civil: Para restaurarla confianza en el sistema electoral.
Managua: IPADE.  
22 See articles in El Nuevo Diario,  “Democratizar los partidos”,  (http://impreso.elnuevodiario.com.ni/2010/08/04/
politica/129396), and “Grupo Promotor de Reformas Electorales: Aboga por un CSE profesional y honesto”, (http://
impreso.elnuevodiario.com.ni/2010/06/23/politica/126756)
23 S. Rose‐Ackerman. 1978. Corruption. A Study in Political Economy. London/New York: Academic Press, and R.
Klitgaard. 1988. Controlling Corruption. Berkeley: University of California Press.
23
In addition, there are other, more specific problems of T/AC program design, which include the
decision to work with weak counterparts within the Presidency; lack of engagement with other GON
entities, in particular line ministries; emphasis on CSO “watchdog” roles as opposed to participation in
institutional change strategies; and an overly‐optimistic approach to civil society participation and
oversight initiatives at the local level. Finally, as well as these design   issues, we also look at some
program management issues, including the ambiguity with respect to the regional nature of the
program; rotation of senior management in the program and USAID and their changing priorities; and
issues in grants management.  
3.1 Anti‐Corruption Program Design
We said above that one of the main problems is the tendency in USAID RFPs to favor program
designs involving multiple and simultaneous interventions across all branches of government, at the
national and local levels and with both governmental and non‐governmental organizations. This
tendency in program design is the result of a technical approach derived from the early studies of
corruption by Rose‐Ackerman and Klitgaard.24  These studies center on the “principal‐agent” problem, in
which citizens or voters (principals) delegate the performance of government tasks to elected politicians
and appointed bureaucrats (agents). The principal‐agent relationship is characterized by information
asymmetry; the problem of corruption occurs when the agent uses this asymmetry in benefit of his/her
own interest.
This theoretical framework has informed anti‐corruption program design in emphasizing
multiple interventions that seek to reduce the discretionary power of agents and increase political,
administrative and legal accountability.25 These programs have tended to favor simultaneous
interventions whether in deregulation, privatization, decentralization, bureaucratic simplification,
administrative and civil service reforms, access to information legislation, strengthened external control
and audit institutions, judicial reform, support for civil society watchdogs, mechanisms for CSO
participation and social auditing,  support for investigative journalism, etc.  Indeed, there appears to be
a single “template” for anti‐corruption programs globally, whether funded by USAID or other bilateral
and multilateral donors.26  
Donor supported programs in developing countries have promoted special offices and
commissions to lead these broad, multi‐pronged anti‐corruption strategies. These types of entities
typically suffer from problems of limited political will and commitment to follow‐through on policy
objectives.  Even when constituted as formal commissions, they are fraught with difficulties.  Indeed,
governments have continued to establish anti‐corruption commissions in spite of ample evidence of
their failure in most countries. There are numerous studies demonstrating that these “direct measures”
to reduce corruption, whether special presidential programs or anti‐corruption commissions, rarely
succeed, since they often lack the required support from political elites and the judicial system.27  
                                                            
24  For a recent discussion of the main issues in the approach developed by Rose‐Ackerman and Klitgaard, see T.
Besley.  2006. Principled Agents: The Political Economy of Good Government. Oxford: Oxford University Press.
26   See the critique in A. Shah.   2007. “Tailoring the Fight against Corruption to Country Circumstances”. In
Performance Accountability and Combating Corruption, Edited by Anwar Shah, 233–254. Washington D.C.: World
Bank.
24
Instead, they are often a way of avoiding substantive policy changes while giving the impression of
political commitment by locating them within the office of the President, albeit with minimal budgets
and low staffing levels.
  
In addition to the reliance on a single executive branch entity (special program, office or
commission), the comprehensive or “holistic” approach by necessity requires simultaneous
interventions across multiple government branches. While the principle‐agent framework identified
multiple factors that contributed to the weak accountability framework for agents, it is not clear from a
practical point of view why the policy response of developing country governments and donor agencies
would require attacking all of these causal factors simultaneously. Again, documented experience from
anti‐corruption programs over the last three decades suggests that this has rarely been an effective
approach to combating corruption. Its success depends on a major political sea change, i.e., the arrival
of a national government with a mandate for sweeping reforms and an explicit commitment from the
executive and legislative to combating anti‐corruption.28 Such opportunities for a “big push” approach
are scarce indeed.
In the absence of such a change, policy is necessarily more incremental. This not the same as
“muddling through”. On the contrary, it requires a shared consensus among donors and governments
on a long term vision of democratic development; the capacity to engage and work effectively with
multiple political actors and government agencies; and the careful sequencing of interventions over a
medium to long term timeframe. All of this, even while maintaining political will and commitment
through successive changes in government. Admittedly, this is a daunting development challenge—but
no more daunting than a once and for all, sweeping reform across all branches of government and
within a single term of office.  
      
3.2 Broad Scope of the RFP
Following on the discussion of theoretical underpinnings of approaches to anti‐corruption
programs in the previous section, here we turn to the RFP design.  In casting the program as “a long‐
term transformation of public institutions and citizen attitudes”, one of the main problems in the T/AC
program, as in other USAID anti‐corruption initiatives worldwide, is the large number of thematic areas
covered in the RFP, reflected in the number of Sub IRs and the range of LLRs under each Sub IR.  The
breadth of the proposed program interventions in the USAID/CAM T/AC program is very problematic
indeed.  
  
Looking just at Sub IR 2.1, summarized in Table 2, there are in fact six LLRs involving a potentially
large number of national government entities, including the Presidency, Ministry of Finance, other
important line ministries, along with the office of the Procuraduria (PGR) and the Controller (CGR).  
While the Nicaragua component of T/AC doesn’t include the work “identifying and addressing systemic
deficiencies” in key line ministries (LLR 2.1.4), in including strategies and interventions to reduce petty
                                                                                                                                                                                               
27 J. Heilbrunn. 2004. “Anti‐Corruption Commissions Panacea or Real Medicine to Fight Corruption?” Washington
DC: World Bank Institute, and  P. Meagher. 2005. “Anti‐corruption Agencies: Rhetoric versus Reality”. The Journal
of Policy Reform 8 (1): 69–103.
28 F. Odd‐Helge and J. Isaksen. 2008. “Anti‐Corruption Reforms: Challenges, Effects and Limits of World Bank
Support”. IEG Working Paper 2008/7. World Bank Independent Evaluation Group.
25
bribes (LLR 2.1.5) it is reasonable to assume that the T/AC program would need to involve some of the
ministries and executive agencies of the national government.
Table 2: Sub IR 2.1 and LLRs
Results Statements T/AC Nicaragua
Sub IR 2.1: More transparent systems for management of public resources by the national government
LLR 2.1.1: National anti‐corruption/transparency strategy completed and implemented √ 
LLR 2.1.2: Implementation of Inter‐American Convention against Corruption Commitments √ 
LLR 2.1.3: Improved national government budget transparency, management and execution √ 
LLR 2.1.4: Systemic government deficiencies identified and addressed in key line ministries
LLR 2.1.5: Initiatives to reduce petty corruption (bribe solicitation) developed and implemented √ 
LLR 2.1.6: Key oversight agencies strengthened √ 
While this reflection might be seen as going beyond the terms of reference of the assessment of
the Nicaragua component, in fact the lack of political and technical realism in the design of the RFP is
the single most important problem encountered. What is even more puzzling was the decision of each
of the participating countries—in this case, Nicaragua—to take up almost all of the Sub IRs and their
respective LLRs in their respective country work plans. Of course, in designing the activities within each
LLR, there were considerable differences, but all of the CAM T/AC program country strategies were
similar in their broad scope and dispersion of resources among numerous activities involving multiple
branches of government.
While the T/AC Nicaragua starting budget of $6,881,680 was increased to $9,658,128 over the
life of the program, even so these resources bear no relation to the magnitude of the program scope
and objectives. This would have been a reasonable budget for just 2 or 3 of the main LLRs under Sub IR
2.1, summarized above in Table 2, i.e., to support a “long term transformation”, through legal reforms,
reorganization, strengthening of internal controls, simplification of policies and procedures, capacity
building for managers and employees, equipment, etc. In Nicaragua, by spreading out the T/AC program
resources over such a large number of government entities, the program could only scratch the surface
of each institution.
3.3 Weak Counterparts in the Presidency  
The broad scope of the RFP in the activities with governments seems to reflect a belief that
there were or would be national anti‐corruption policies in place; a corollary assumption seems to have
been that the existence of an anti‐corruption strategy in the office of the President would bring with it a
reasonable level of cooperation on the part of individual ministries, executive agencies and control
institutions. The T/AC Task Order Annex 1 was explicit on this point in supporting a whole of government
anti‐corruption strategy:   
“Under this Component [SubIR 2.1], the Program will support a National anti‐corruption
strategy. C&A will collaborate closely with the “Oficina de la Presidencia” (leading the anti‐
26
corruption multi‐donor fund), the Office of Public Ethics (OEP) in charge of IACC follow‐up and
reporting...”29
As we will discuss in further detail below, this corollary was not borne out in the execution of the T/AC
program in Nicaragua.  
The T/AC program dedicated significant time, effort and resources to working with weak
counterparts within the Presidency. During the first phase of the program, the main GON counterpart
was the Presidency and specifically the Office of Public Ethics (OEP) and the Secretary for Strategic
Communications (SCE), neither of which exercised significant institutional leadership. Experience of
many developing countries suggests that these kinds of executive branch counterparts are rarely
effective channels for generating and sustaining change.   
It is worth pointing out that in the case of T/AC Nicaragua, the main counterpart was not even
constituted as an autonomous commission.  What is more, the existence of two counterparts within the
office of the Presidency (SCE and OEP) was an added complication, as they were constantly competing
for donor resources and leadership. Several interviewees were of the view that many of the problems
experienced by the Nicaragua T/AC program in implementing activities during the first year were caused
by this simmering conflict. In any case, the main point here is that neither of these two offices within the
office of the Presidency in Nicaragua had strong political leadership or budget resources—hence, they
had little or no influence with other executive branch entities, and certainly not with other branches of
government.   
One clear example of the weakness of T/AC Nicaragua’s main counterpart in the GON was the
difficulty in carrying out the “Voluntary Transparency Strategy” (EVT), a pilot program for improving
access to information in selected line ministries and agencies by establishing web sites.  The proposal
was floated by the SCE in the second quarter of the T/AC Nicaragua program. Only in the fifth quarter,
more than a year later, did the program initiate an activity in support of EVT, which was an on‐line test
of the web sites previously established by eight participating entities. The results of the test were
communicated to the participating GON entities by the SCE, but only two of them agreed to implement
the recommendations and only one followed through (Ministry of Finance).  Indeed, at the end of the
second year, SEC made a request for support from the T/AC program to assist it in “promoting” the EVT
among government entities.  
  
3.4 Weak Engagement with GON Entities
And despite these obvious weaknesses, the program did not shift its strategy to engage other
key government entities. For example, while one of the LLRs was to improve national budget
management and transparency, outside of the EVT project, T/AC Nicaragua did not work at all with the
Ministry of Finance or individual line ministries to strengthen the budget process. Nicaragua clearly has
serious technical and administrative deficiencies in many aspects of budget management, whether in
program budgeting, application of medium term budget frameworks, incorporation of decentralized
institutions and state owned enterprises into the national budget, etc. From the outset (and not just
                                                            29 See USAID/CAM Anti‐Corruption, Transparency and Accountability Task Order. Annex 1. “Nicaragua Annex.
Country Specific Interventions”. Page 3.
27
during the FSLN government) the T/AC program emphasis in this area of budget transparency was on
CSO oversight, rather than on support to the GON.  
In the final analysis, the absence of institutional change strategies in specific line ministries or
other agencies reflects the decision not to implement LLR 2.1.4 in Nicaragua, “systemic government
deficiencies identified and addressed in key line ministries”.   Again, this raises the issue of strategic
choices. The T/AC program dedicated significant time and effort (through a grant to Hagamos
Democracia) to the innocuous purpose of getting members of the Assembly to report on how they spent
their small budget allocations,  while ignoring what the Task Order acknowledged to be rampant, large
scale and petty corruption in executive branch agencies.  How could the program hope to be effective in
reducing corruption experienced by citizens, without working in those government entities which
generate corrupt practices?  
The decision not to engage counterparts in line ministries, autonomous agencies or control
institutions was reflected, too, in the absence of institutional assessments, capacity development plans,
etc., during the first two years of the program—nothing that resembled even in a passing way a strategy
for inducing “institutional transformation” of selected national government entities. Only in Year 3, and
in a worsening political context, did the T/AC program begin to support the design and application of
some diagnostic tools to identify issues of transparency or corruption in specific government entities. In
that they were not designed in consultation with the leadership of the counterpart GON agencies, nor
framed within a coherent plan for institutional change, in practical terms these exercises had no effect
at all.
Related to the previous points, one of the notable weaknesses of the T/AC Nicaragua
component was the absence of formal commitment from government counterparts to work towards
specific objectives. In the last twenty years there has been a worldwide movement to “reinvent”
government, which has generated an impressive range of change management approaches and tools.
One lesson from this experience is that supporting institutional change in the public sector requires the
political will of the executive, combined with vision, leadership, and commitment by ministers and
senior managers in specific government entities to carry out actions in support of reform objectives.
These are usually set out in policy documents and detailed in action plans. The T/AC program was
unable to initiate anything similar: for example, two years into the program the QPR narrative informs
that “Collaboration and communication with government institutions have continued. For example,
during this reporting period policy dialogue on relevant transparency issues with the National
Procurement Office (DGCE) has continued”.30  What the objective of this dialogue might have been, or
what impacts it might have had is not made clear in the QPRs.   
This design fault is one of the reasons for the paucity of substantive program impacts at the
national level. How can a program expect to generate “institutional transformation” with small, one‐off
interventions spread across multiple agencies? A typical impact statement for the T/AC Nicaragua
program is: “During this Fiscal Year, the Program made substantive progress in promoting transparency
and accountability in the governmental sector. GON officials (both at the national and local levels)
received anti‐corruption training on key topics such as: social auditing techniques; gender and
transparency; political party finance; Inter‐American Convention against Corruption and the United
                                                            
30 See C&A. QUARTERLY PERFORMANCE MONITORING REPORT NO. 13 PERIOD COVERING APRIL 1, 2007 TO JUNE
30, 2007, P. 6.
28
Nations Convention against Corruption; internal control; legislative transparency; access to public
information; and techniques for investigating corruption cases.31
While the T/AC Nicaragua program included LLR 2.1.6, “key oversight agencies strengthened”,
the engagement with the CGR was sporadic and again consisted of one‐off training activities, isolated
from institutional assessments, capacity‐building plans, etc. For example, in 2007 the T/AC Program
worked with the CGR to promote the use of new approaches to internal control—“control self‐
assessment”—through “workshops where more than 130 public employees from 6 government
institutions were trained on internal control and control self‐assessment tools”, including new process
software. The workshops promoted efficiency and efficacy in operational procedures, risk management,
adequate use of public resources, ethics and transparency and accountability. Subsequent QPRs make
no mention of how this was incorporated into the six institutions, whether there were changes in
policies, procedures, etc.
The description in the QPRs of an initiative to put up “instructional signs” in several ministries is
perhaps the best example. While it might make for a good picture for a report, this initiative was not
framed within a coherent change strategy, for example, including process reengineering, reduction of
red tape, training for employees in customer service, changes in office hours or locations, application of
IT to e‐government approaches, or use of performance measures of customer satisfaction, average time
to complete a transaction, average wait times, etc.  One of the GON counterparts interviewed for the
assessment described this particular intervention as an example of “pañitos tibios” (i.e., the cool cloths
applied to the forehead to reduce a fever).  
In spreading its resources among a wide range of short term, one‐off activities, the program was
unable to build effective interventions through engagement and dialogue with decision makers—
politicians and senior management teams—in a few selected government entities. And even if it had
attempted to do so—there is no evidence of such an approach—it probably wouldn’t have been able to
bring to the table sufficient resources to be of interest to a line ministry. Its resources were spread too
thinly among a large number of program interventions to be able to fund large‐scale reforms and
change management projects in individual GON entities. Again, our view is that this problem originates
in the RFP design, and the implicit belief in the virtues of a “comprehensive” approach to corruption
prevention.
3.5 Emphasis on CSO “Watchdog” Role    
To compound the problem of program dispersion, the RFP also includes a broad range of
activities aimed at engaging civil society, whether in Sub IR 2.2 related to local governments or Sub IR
2.3, in the national ambit. The focus of the program was on supporting NGO interventions in oversight
of government, and in disseminating and communicating the results through events, publications and
coordination with journalists and media organizations. In fact, as was discussed above, most of the
spending in the Nicaragua component was focused on work with NGOs and CSOs, promoting the role of
NGOs as “watchdogs” at the national level, and promoting citizen participation in planning, budgeting
and social auditing at the national and local levels.  The main program achievements are fruit of Sub IRs
2.2 and 2.3, not Sub IR 2.1.  
                                                            
31 This is taken from the C&A, QUARTERLY PERFORMANCE MONITORING REPORT NO. 14, PERIOD COVERING JULY
1, 2007 TO SEPTEMBER 30, 2007. P.7.
29
Despite the laudatory achievements of the CSOs working in developing tools for oversight of
national government, in particular IEEPP and Hagamos Democracia, these initiatives were not linked to
reform initiatives within the GON.  Experience in anti‐corruption strategies in other countries suggests
that involving civil society in reform initiatives is useful and productive, for example by establishing
coalitions, or mixed governmental and non‐governmental “task forces” to support and monitor
implementation of short‐term change strategies in targeted entities.  In this approach, the role of CSOs
is to exercise pressure for sustained commitment of politicians and senior managers to follow through
on their commitments to change.
This point is crucial, not least because many of the challenges of anti‐corruption programs can
be characterized better as “collective action” problems, rather than “principal‐agent” problems.   There
is an absence or scarcity of institutional actors willing to act as “principled principals”.32 In contexts of
endemic corruption, “we should expect monitoring devices and punishment regimes such as suggested
by the principal‐agent framework to be largely ineffective”.33 In these contexts, external pressure on
government for increased accountability (i.e., CSO watchdogs) may not be as effective, as for example,
an agreement on new “rules of the game” within a particular institution, whose implementation is
subject to oversight and verification by multiple actors, including “agents” (politicians and managers)
and principals (CSOs, private sector, media, academia, etc).  To the extent that the agreement holds, the
actors will begin to change their expectations and be willing to sustain their support for institutional
transformation.
Of course, this approach requires capacity to engage government counterparts in line ministries
and other agencies, develop change strategies and short‐term action plans, and at the same time
involve CSOs in design, implementation and monitoring. As we observed in the previous points, the T/AC
program was not effective in this sense; hence there were no real opportunities for focusing CSO
oversight on supporting GON commitments. Arguably, with the change in national government and the
increased animosity towards CSOs, the opportunities for constructive cooperation between civil society
and government were significantly reduced. However, even during the more favorable context of the
Bolaños government the T/AC program took no steps in this direction.  The default role strategy was to
support CSOs as “watchdog” entities (or to research and propose legislative reforms in key areas such as
political party finance). While these are valid roles, they are not the only role, nor necessarily the most
productive role.   
With respect to the small grants for media organizations and CSOs involved in campaigns, some
of the T/AC program counterparts interviewed noted that the radio programs were without doubt the
most controversial.  The radio programs were broadcast by media outlets with an explicit and widely
recognized anti‐FSLN editorial slant.  While USAID funding specified that the contents be non‐partisan,
this was not always the case; moreover, even when the programs maintained  neutrality, for example in
promoting voter registration and participation, according to these observers, the “sub‐text” was evident
                                                            
32 See discussion in L. Lawson. 2009. “The Politics of Anti‐Corruption Reform in Africa”. Journal of Modern African
Studies 47 (1): 73‐100.
33 A. Persson, B. Rothstein and J. Teorell. 2010. “The failure of Anti‐Corruption Policies: A Theoretical Mis‐
characterization of the Problem”.   QoG Working Paper Series 2010: 19. The Quality of Government Institute.
Department of Political Science, University of Gothenburg, P. 3.
30
to all.   From the perspective of the T/AC counterparts, this was damaging to the program and to
USAID.34
3.6 Support for Local Civil Society
The justification for including the local focus in the civil society component was not immediately
clear. In Nicaragua, like all Central American countries, local governments’ share in overall public
expenditure is quite small, ranging from about 5% to 10%. The bulk of spending—and corruption
opportunities—is in the national executive, i.e., line ministries and agencies.  Again, it seems like there
was a preference for a “comprehensive” approach to corruption, rather than a set of strategic choices.
As in LLR 2.1, this also led to dispersion of program resources through a series of grants to CSOs, each
working in several municipalities. Several of the CSOs interviewed, while praising the willingness of the
program to experiment with new approaches, were critical of the short‐term focus. As one CSO director
put it, referring to participatory budgeting exercises, “real changes in the relationship between local
governments and citizens require sustained interventions over several fiscal years, not a one‐time
experiment”.
There also seems to be an unstated assumption in the decision to focus on local level activities
to support transparency and accountability—that because of the close proximity of government to
citizens, it is somehow “easier” to support effective participation in decision making and oversight (i.e.,
social auditing).   In fact, research and evaluations on international experience with decentralization
suggests that it can be precisely the opposite, owing to extreme levels of local state capture by
entrenched elites.35  For example, municipal councils in Nicaragua, like those in other Central American
countries, routinely meet behind closed doors, despite legal provisions to the contrary.   Mayors use
public procurement opportunities to “placate” the municipal council members.  Members of the public
rarely have access to key documents referring to planning, budgeting, spending or contracting.  Indeed,
even opposition council members are denied access to these documents in many Nicaraguan
municipalities.   
At the same time, local civil society activists are exposed to direct pressure and intimidation.  In
our interviews with youth leaders, for example, we were told that attempts to carry out social auditing
of municipal investments by local youth groups were met with intimidation directed at their parents by
municipal authorities, including the threat of lay‐offs from public sector employment. Former C&A
program staff indicated that the local level social auditing activities required prior approval from the
mayors, and the political negotiations ensured that it focused on “safe” programs and projects.36  
                                                            
34 It should be noted that one of the participating radio stations is owned by the family of an opposition candidate
in the 2011 national elections. As one of the interviewees noted, this station is notable for its “belligerence”
against the FSLN.
35 The classic explanation of this danger is: R. Prud’homme.  1995. “On the Dangers of Decentralization,” World
Bank Research Observer, 10, 2, pp.201‐20. A more recent review of theory and evidence on this issue is A. Shah.
2006. “Corruption and Decentralized Public Governance”. World Bank Policy Research Working Paper No. 3824. 
36 One of the former staff members was asked the question as to whether the mayors would have allowed the
exercises to go ahead in partnership with the CGR in the framework of audits of municipal spending, along the
lines of the pilot programs funded by the World Bank in Colombia and Honduras in recent years.   “Absolutely not”,
was the reply.
31
Likewise, it seems that the social auditing activities have always involved a great deal of negotiations
with mayors to allow access to official information on budgets, programs and projects, procurement,
etc.  
There were no local “access to information” regulations approved by councils in the
participating municipalities. This was confirmed by several CSOs, who admitted that the T/AC program
grantees tended to use “moral suasion” to convince mayors to open up decision‐making.  Thus, without
taking anything away from the authentic desire on the part of citizens for better governance, in many
cases this demand was in a sense mediated by the T/AC program.   At the same time, the grantees
working in this area recognized that in most of the targeted municipalities it has not been possible to
maintain these mechanisms for citizen participation. This is true even in those municipalities which
passed regulations to implement the Citizen Participation Law. Several interviewees thought that an
effective program would require more sustained support over several years in order to build a sustained
demand for good governance.
While the program did support the passage of citizen participation ordinances in four
municipalities, this initiative was in the closing months of the program; hence there was no follow‐up
support.   Interviews with T/AC former grantees suggest these ordinances are now dead letter in the
respective municipalities.37
This point requires a reflection on the “impact model” of local level interventions. In reviewing
the T/AC Nicaragua program documents and interviewing program counterparts and C&A staff, there is
a lack of clarity as to the expected impact of these interventions.  Whose attitudes are they changing?  
How will they reduce corruption?  How will they be sustained in the long term, once the program is
completed?  One major concern is the absence of a link between the support to CDMs and CSOs for
planning and budgeting and social auditing, and the elected municipal councils. Are opposition council
members interested in promoting citizen participation and oversight?  Why the CDM and not the council
as a locus for oversight initiatives?  Is the local political system so dysfunctional that the council has no
role in oversight?   
The sustainability issue is especially important. One of the program design issues was the high
cost of promoting citizen participation and oversight.  The costs of supporting participatory budgeting
exercises in each municipality were in the order of $20,000 for a single fiscal year. Whether T/AC in fact
had the resources to work effectively at both the national and local level was resolved in favor of the
latter. It is not clear whether this decision was based on an objective evaluation of program results to
date.    
As we discuss elsewhere, some of the major achievements in phase 1 of the program were the
result of support to NGOs working at the national level, engaged in policy analysis, budget oversight,
legislative drafting, and policy debate and dialogue. These activities were just starting to get off the
ground when the decision was made to eliminate the activities at the national level and focus exclusively
on the local level.  This, despite the concerns about cost‐effectiveness and sustainability of supporting
citizen participation and social auditing at the local level.
                                                            
37 This assertion by former T/AC grantees should be taken with benefit of inventory. We did not have the
opportunity to verify this first hand. It would be useful for the new local government program to carry out a rapid
assessment.
32
It is our perception that this program decision was based on immediate political considerations.  
From the explanation set out in Modification 29, the review of QPRs and the Final Report, plus the
interviews with the USAID Nicaragua program manager, former program managers of C&A and the main
T/AC counterparts at the national level, the decision to focus on local level activities was in response to
Mission concerns about the upcoming 2008 municipal elections—concerns that were subsequently
justified by the amply documented electoral fraud in more than 40 municipalities. Nevertheless, the
question is whether it was necessary to eliminate the entirely the national level activities being
implemented by NGOs.
  
3.7 Use of Objectives and Indicators
The problem of the broad scope of the T/AC program was compounded by a lack of clarity on
program results and how to measure them. Indeed, one of the most glaring issues in this respect was
the lack of performance measures to reflect the proposed transformation of public institutions. To begin
with, it is not clear whether the objective set out in the RFP, “to reduce the level of corruption that is
experienced by citizens in the participating countries”, was ever incorporated into the program
indicators. The Final Report submitted by C&A makes no reference at all to this objective. At the same
time, in all of the reports, the emphasis was on “transparency and accountability”, rather than
corruption.
This shift in the main program objective between the Task Order and the T/AC narrative reports
might also help to explain why, at least in the Nicaraguan component, there was no initial base line
assessment to measure the level of corruption experienced by citizens. Was corruption spreading
quickly?   What were its levels in 2005 and 2009? Did the program reduce perceived or experienced
corruption? What empirical studies on corruption that were conducted, in fact were only carried out in
the second and third years of the program, and they were apparently not used to measure program
results. Moreover, for reasons that will be examined below, in some cases the results never were
disseminated at all.
 
With respect to the Sub IRs 2.2 and 2.3, it is never made clear exactly what public attitudes were
being changed.  Opinion surveys show that Nicaraguans see corruption as an important policy issues and
want government to do something about it.38   Was the program intended to reinforce these critical
attitudes? Or raise public expectations and pressure for a government response?   Or measure the
institutional transformation in the public sector by the variation in public perception about corruption
prevalence?  The results indicators presented in the QPR narratives and the Final Report are limited to
the number of people attending the T/AC program training, civic education or lection participation
activities.  
For example, despite the strong emphasis on civil society participation and oversight of local
government, there was no indicator to measure improved citizen perceptions of local government
transparency and accountability. While the QPRs mention support for an “over sample” of the LAPOP
survey in the T/AC program municipalities, it appears that the base line was never completed; hence
there was no end‐term measure, nor a comparative analysis of the change in perception over the
program period.
                                                            
38  The surveys conducted by LAPOP, Latinbarometer and local survey firms coincide in this aspect.  Corruption is
always included in the list of major policy issues of concern to Nicaraguans.   
33
While it might be objected that a USAID program cannot single handedly reduce corruption
levels in the entire public sector, an appropriate technical solution would be to focus activities on
reducing corruption in individual institutions and measure substantive progress through report cards,
customer surveys, corruption victimization studies, etc. But in proposing only to enhance government
capacity to promote transparency—apparently across a wide spectrum of executive agencies,
legislature, local governments and control institutions—the program avoided even attempting to reduce
corrupt practices in a single institution or operating unit. As we discussed above, early on in the program
the decision was made not to focus resources on effecting institutional transformations in specific
entities.   
Again, this problem reflects the weaknesses in the RFP design and the lack of realism about the
kind of interventions required to transform public sector institutions. In this context, it is hardly surprising
that the program would have no measures of impact in relation to reducing corruption in targeted public
sector institutions.    
Overall, it seems that measuring impacts, whether on levels of corruption, citizens’ attitudes or
institutional transformations, was not a priority.  Indeed, from the review of the program documents, it
is not clear whether the program had a functioning M&E plan that would be useful for program
management, i.e., a set of indicators that would inform decisions about program strategies and design
of activities. From the QPR narratives it appears that the proposed “M&E plan” took more than two
years to design and approve and apparently was not used as a means of managing the program
interventions during the first half of the program implementation period.39 Neither the QPR narratives
nor the Final Report refer to the program performance indicators at all. In this respect, it should be
noted, too, that the present assessment was unable to review the T/AC Nicaragua M&E plan, the design
of the performance indicators, or M&E reports. For this reason, it is not possible to explain how the plan
actually informed program decisions.  
In this sense, the overall technical management of the program, whether on the part of
USAID/CAM or the contractor—or both—seems to have been deficient. This might reflect in part the
problems encountered in managing a regional program, which will be discussed in the following section.  
In any case, it is difficult to explain how the main objective of reducing the levels of corruption
experienced by citizens was morphed into a proposal to “to promote and obtain greater transparency
and accountability”.40 
                                                            
39 In the Quarterly Performance Report No. 11, submitted in October 2007, C&A reported that the Nicaragua M&E
plan had not been approved as yet. See: Casals & Associates, Quarterly Technical Performance Report No. 11.  
Period covering   July 1, 2007 – September 30, 2007 (4th Quarter of FY 2007) page 17, which states:   “I. KEY
ACTIVITIES: Please note that the M&E Plan for this Program has not yet been finalized, therefore no indicators
have been included in this report”.
40 See Casals &Associates. USAID/CAM Anti‐Corruption, Transparency and Accountability Program. Final Report.
Nicaragua.  Page 5. 
34
3.8 Regional Scope
One aspect that stands out in the management of the program was the inability to implement
activities with a regional scope.  The original design called for a regional CTO and a COP both based in
Guatemala.  What appears to have occurred, from interviews with program staff and USAID officials, is
that neither the CTO nor the COP was able to dedicate sufficient time and effort to building‐in activities
to promote and reinforce synergies between country components.  
Despite the existence of budget resources in the form of a “Multi‐Country Opportunity Fund”,
by the end of Year 1, this aspect had disappeared from the QPR narratives, except for the occasional
reference to one‐off, bi‐lateral activities between organizations in different countries. For example, in
August 2007,  T/AC Nicaragua funded the travel of two NGO directors to attend the IV Central American
Summit on Political Party Finance organized by TI.  But these were few and far between and there was
no follow‐up to support application of “best practices” or other learning formats.41 This tendency was
reinforced with the transfer of responsibilities for regional programming from the T/AC program
COP/Country Director in Guatemala to the Casals & Associates HQ. By Year 3 the regional program
meetings had ceased. The occasional visit by HQ managers was usually focused on resolving urgent
management issues.
In interviews with the T/AC program partners and grantees, there was a recurring issue of the
use of international consultants or C&A HQ staff as technical resources.   Several of the Nicaraguan
partner organizations mentioned that C&A did not draw on technical resources from NGOs and
government in the other participating countries, but rather preferred to use its own “roster” of
international consultants. In this way, C&A did not take advantage of opportunities for building peer
networks and exchanges in the region. The partners and grantees were generally very critical of this
aspect, calling into question the logic of a regional program that was unable or unwilling to use human
resources from within the region.   Several noted that the regional dimension was largely limited to
travel by USAID and C&A program staff.
3.9 Program Management Issues
The Nicaragua component suffered from a series of management problems, not least among
them the rotation of senior program management: the regional COP (effectively three over the length of
the program) and country Directors (also three over the length of the project, along with more than six
months of interim managers).   This rotation of program management was exacerbated by changing
priorities of USAID/Nicaragua management, in response to the short term political context. The former
C&A program staff described this in terms of “turbulence”.
In the first year, there were long delays in start‐up (mobilizing key personnel, setting up offices,
and hiring local staff). Beyond the start up problems, a review of the QPRs shows that it was not possible
to implement most of the activities set out in the FY2005 Work Plan, beyond the initial discussions with
program counterparts. In this first year the program was unable to navigate the internal politics of the
Office of the President to provide support for the OPE’s activities; there were no initiatives with
                                                            
41   One of the QPRs refers to a breakfast meeting with GON officials that had attended a regional TI event,
reporting that there would be follow‐up to ensure application of best practices. It was never mentioned again in
subsequent QPRs.  
35
executive branch entities nor control institutions; nor was the T/AC program able to define concrete
projects with CSO partners.  Reviewing the QPRs, there are numerous activities that are mentioned time
and again in successive QPRs as programmed for the following quarters; a glaring example is support for
a “Transparency Circle”, which appeared in six consecutive QPRs before it was finally carried out in the
eighth Quarter.42
Several of the T/AC program partners interviewed in this evaluation referred to the first year
activities as amounting to “a lot of exploratory meetings”. Key activities such as the selection of
municipalities were also delayed considerably, owing to problems with the selection methodology and
its application. While the program awarded a grant to EyT in Q3, but by the end of Q4 it had still not
initiated activities, because the municipal selection had not been completed. The selection was
completed only in Quarter 5. Subsequently, the program had to renegotiate with some of the initial
grantees the geographic focus of their activities, which proved to be damaging for both the program and
the grantees in their relations with local institutions.
As was discussed in Section 1, in the second year of the program, with a new country Director,
there was considerable progress made in implementing activities in function of program objectives.  But
the country Director was replaced again in the fourth year, owing mainly to problems of
communications and lack of consensus on program orientation with the new Mission management.43
The Director was focusing efforts on maintaining an anti‐corruption policy agenda, in part through a
series of diagnostic studies, evaluations and policy analyses aimed at influencing public opinion. For its
part, the Nicaragua Mission management was increasingly concerned about the upcoming municipal
elections, issues of campaign finance, transparency in use of public resources, management of the voter
registry, obstacles to youth voting, etc.
In analyzing the difference in opinion between the country Director and the Mission, the issue
appears to be not so much the increased emphasis on local elections, but the decision to eliminate all of
the activities related to policy debate and dialogue at the national level. As we discussed above, with
Modification 29, the program became exclusively focused on the local level. Whether it was in fact
possible to engage the GON on policy debate in the area of transparency and accountability is open to
debate; what is unequivocal is that in responding to the immediate political conjuncture, the changes to
the Task Order eliminated the on‐going activities with important NGO partners in oversight, social
auditing, policy analysis and advocacy.
Not surprisingly, the main program partners and grantees that were involved in this kind of
activity were very critical of USAID’s decision in this respect, referring to the “short sighted” nature of
the Task Order modification, on the one hand, and the “politicization” of USAID programs on the other.
Again, while all of the organizations consulted recognize that formally the small grants program to
                                                            
42 QPR 8 mentions the support for the first ever Transparency Circle upon the return of a Nicaraguan delegation
from an event in Guatemala: “the Program along with the active participation of the delegation launched its first
Transparency Circle; a concept centered around the idea of promoting dialogue between the various sectors of the
Nicaraguan society on transparency”. Why this simple concept required a visit to Guatemala and two years to
organize is not clear.
43  While from the memos and emails back and forth between the program and the Mission, it seems that there
were also personality issues, the substantive problem was a lack of technical consensus on program strategy and
activities.
    
36
support electoral activities did not support partisan political activity, they argue that owing to the
grantee selection, contents and timing of the initiative, it was perceived by all concerned as essentially
political. Several of the partners considered that the modification was dictated by short term foreign
policy concerns, as opposed to a longer term vision of how to build institutional capacity of civil society
organizations to support democratic development.
Nor did the decision to eliminate entirely the activities at the national level give USAID good
value for money. Many on‐going activities and sub‐grants were cancelled outright. Ironically, as we have
discussed above, the enduring impacts of the program were felt in ongoing activities of NGOs at the
national level, whereas the local level activities virtually ceased once the T/AC program was completed.
Some of the studies were in fact concluded, but either C&A or USAID prohibited their dissemination. The
inconclusive activities include the mapping of IACC compliance in executive agencies; the results of the
survey of youth opinions; the replication of the LAPOP survey in the “oversample” of T/AC local
government; the study on the costs of corruption; and the proposal on administrative simplification
(reduction of red tape).44  
     
3.10 Grants Management  
Related to the issues raised in the previous section, in the interviews with program partners
there were constant complaints about the management of the grants. Some grantees complained about
the “original” grants awarded during phase 1 of the program, to support citizen oversight and
participation in budgeting (nationally and locally), IAAC compliance, elections/campaign finance reform,
or diagnostic studies of corruption prevalence.  Others referred to the small grants fund created by TO
Modification 29, to support civic education and participation in the run‐up to the 2008 municipal
elections.  
With respect to the grants awarded in phase 1, several partners complained that the program
forced NGOs into partnerships and coalitions, rather than allowing NGOs to organize coalitions
according to affinity and interests. A concrete case is the attempt by the program to partner two NGOs
to carry out budget oversight activities. Only after almost eight months of failed attempts to join these
two unwilling partners did the T/AC program relent and award a grant to one of the NGOs.45  In other
instances, notably the grants to support work on IACC compliance and political party financing, the
NGOs interviewed reported that they were forced into presenting joint proposals.  One of the NGO
leaders asked, “If there were limited funds for the activities, too many proposals and a competitive
process, why couldn’t the program just decide on the best proposals instead of insisting on
“partnerships”?
The perception on the part of NGOs with respect to the “interventionist” nature of the program
during the first phase was reinforced with the small grants fund executed during the second phase. As
was mentioned above, several of the smaller NGOs complained that they were obliged to rework
                                                            
44  Some of these may have been completed; others cancelled while being implemented, and others just getting to
the design stage.  It was not possible from the QPRs to get a complete picture.   
  
45 Here the reference is to the attempt to join IEEPP and CISA. The grant was eventually awarded to IEEPP. CISA
ended up presenting four separate proposals over two years, at the request of the T/AC program, without ever
receiving funding.
37
proposals in function of USAID’s geographic priorities, without taking into consideration their previous
experience and relationships. Two of the larger NGOs interviewed reported that owing to the small size
of the grants and the onerous reporting requirements, they had opted not to present proposals,
however, in one case the program pressured the board of directors into insisting that the Director
present a proposal.   
Another aspect of this problem was the vetting of reports and studies carried out by T/AC
program grantees, which was felt both in the “original” grant program and the small grants fund
established in Modification 29. One of the major program grantees reported that four of the technical
reports produced under the grant were never released or disseminated owing to either C&A’s or
USAID’s refusal to approve them.  Other major grantees mentioned C&A’s insistence on vetting and
editing materials and reports not only for form but also for contents, which they considered excessive
considering that the work was done under grants rather than contracts. One experienced NGO director
observed that from his perspective “C&A staff didn’t understand the difference between a grant and a
contract”. These criticisms were aired by NGOs which received only one grant and by others which
received multiple grants.   
Almost all of the grantees considered that the program exercised excessive oversight of
invitations to activities and events, which according to them was in effect even before the 2006
elections. While this was a requirement of the State Department rather than USAID/Nicaragua, for the
T/AC program grantees and their local counterparts this was too fine a distinction—in the final analysis
it was seen to be intrusive and damaging to the NGOs’ image as non‐partisan actors. In the interviews
there were constant references to lack of understanding by the Mission that to be effective in
influencing policy, NGOs needed to be able to engage with government‐‐any government—even if it is
to point out failings of policies, to expose lack of compliance with laws, etc.  As one of the NGO leaders
interviewed for this assessment put it, “long after the T/AC program is gone we will still be here, trying
to change things”.
In addition to these problems, there seems to have been a serious problem with the program
burn rate and the obligation of funds that affected the grants program. Apparently in the haste to
increase program activities in 2008 the T/AC program effectively ran out of funds, which led it to curtail
disbursements to grantees.46 This problem was confirmed by interviews with former C&A staff
members, who attributed it to weaknesses in financial planning and miscommunication between the
field offices and HQ. The problem was subsequently resolved through a contract modification to
increase the obligation of funds, but by then the damage was done; one of the NGOs affected by the
decision reported that C&A had not explained the causes of the problem, but rather in meetings with
the COP it was attributed to USAID “cutbacks”.   
The assessment concludes that the program support for NGOs was late in starting (major grant
activities with NGOs started in the second year), short in duration (the modification 29 essentially
eliminated the activities of NGOs working in policy or at the national level), at times overly involved in
day to day management and more importantly, it was not designed to contribute to building NGO
capacity in this field. Despite the focus of the RFP on “institutional transformation” the design of the
program work plans and activities did not incorporate a long term strategy for capacity building of NGOs
                                                            
46 According to interviews with former C&A staff, the conflicts with C&A on this issue led to the decision on the
part of two of the NGO partners not to present proposals to the second round of the small grants program in 2008.
38
in the field of transparency and accountability; rather, the support was always framed in terms of sub‐
contracts for specific activities, at most a year in duration, many much shorter. The small grants fund,
established by TO Modification 29, by definition supported program activities of only several months in
duration.  
Section 4: Lessons Learned  
Overall, looking at the resources channeled toward the Nicaragua component of the regional
T/AC program, one of the first conclusions that can be drawn is that despite receiving the largest
country share of T/AC resources, the achievements were very limited indeed with respect to the Task
order’s objective of “transformation of public institutions” with the purpose of reducing levels of
corruption.  While this might be attributed to the increasingly adverse political context in Nicaragua, as
we discussed there were also considerable problems in the design of the RFP, the decision to implement
work in almost all of the LLRs, and resulting dispersion in resources, along with a series of problems in
design and management of program activities. In what follows we outline the main lessons learned from
the T/AC Nicaragua experience.  
4.1 Program Counterpart in GON  
One of the main lessons learned in the T/AC Nicaragua program, and which confirms international
experience documented in academic research and evaluation, is the difficulty of hinging program
interventions in the public sector on the Presidency. The decision to work with the two offices of the
Presidency (SCE and OEP) was not based on a realistic assessment of the political weight of these offices
and its influence on other public sector institutions.  Even had the Presidency developed a coherent anti‐
corruption plan, it is doubtful that the SCE or the OEP would have had the wherewithal to lead the
implementation of such a plan. Whether the T/AC program followed USAID’s lead on this decision was
not clear, but in any case it should have been subject to careful review and discussion with the GON
beforehand.
4.2 Dispersion of Program Resources
Another lesson, which again reflects and reinforces international experience, is the difficulty in carrying
out and sustaining simultaneous anti‐corruption reforms by spreading program resources across
multiple branches of government and numerous government entities. In dispersing program resources,
it is difficult to interest and engage decision‐makers in individual line ministries and agencies in reform
initiatives. The large number of SubIRs and LLRs selected for the T/AC Nicaragua component meant that
the program was unable to bring resources to the table in discussions with potential counterparts;   
hence it generated scant interest.
4.3 Use of “Horizontal” Interventions
While it worked with several GON entities, in fact the T/AC program gave preference to “horizontal”
interventions, for example, sensitizing staff from several line ministries and agencies on a particular
policy issue or training on a particular management approach or tool (i.e., control self assessment,
improving access to information, or implementing client friendly measures such as instructional signs).
These interventions were typically one‐off, unconnected to change strategies or plans of the
participating GON entities.   There was no follow up and in the final instance the T/AC program was
39
never able to identify or measure specific impacts of these kinds of training exercises within the
participating institutions.
4.4 Engagement with Line Ministries
Related to the previous points, the T/AC program did not engage effectively with line ministries or other
agencies. International experience in public sector reform shows that institutional transformation
requires not just a national policy or plan, but also change‐management strategies involving dialogue,
planning and joint work plans focusing on achievement of specific results and activities, including the
definition of inputs, outputs, and performance indicators.  There were no such strategies in the T/AC
Nicaragua component. As a result, the program could demonstrate no measurable progress towards the
stated objective of reducing corruption.  
4.5 Watchdog Role of National CSOs  
The program conceived of the role of CSOs as essentially that of a “watch dog”, to press for increased
accountability of decision‐makers. This proved an effective strategy up to a point. Several NGOs have
been able to build expertise in oversight of GON policymaking, planning and budgeting. However, this
role was and continues to be essentially critical, identifying problems but not contributing to solutions.  
The program did not explore opportunities for more constructive roles, for example, brokering
cooperation between GON and CSOs in designing, monitoring and sustaining institutional
transformation within specific entities.  In that way, it may have forgone opportunities to contribute to
less confrontational relationships between the GON and CSOs involved in public policy debate and
deliberation.
4.6 Mixing Government/CSO Interventions
One of the notable problems observed in the T/AC Nicaragua program was the mix of support of GON
anti‐corruption policies (albeit a minor component, for the reasons discussed above) with support to
CSOs in their “watchdog” roles (the major component).  This mix of strategies was problematic for the
program in the PLC government, but even more so in the FSLN government.  Increasingly, as several of
the interviewees noted, the T/AC program was identified as having a “civil society” bias, which in the
latter administration was equivalent to an “anti‐government” bias.  Here we get back to the problem of
focus and strategic choice.  While in some contexts it might be appropriate, it is possible that in the
Nicaraguan political context, the T/AC program would have been more effective choosing one or the
other strategy, i.e., without the mix of government/CSO interventions. Again, this gets back to the RFP
standard “template”.
4.7 Rationale for Local Level Interventions
Governance programs need to make strategic choices about arenas of action. Sometimes difficulties in
working with national government agencies might merit a re‐focusing towards local governments. That
certainly has been the case in Nicaragua. But oversight and social auditing exercises at the local level are
fraught with political difficulties too. This assessment is left with unanswered questions about the real
impact of local level accountability and social auditing exercises. The T/AC program relied heavily on
“moral suasion” by the program Director to convince mayors to “allow” citizen participation and
oversight. And once the program activities were completed, in many of the localities, things went back
40
to normal, apparently even in those local governments in which the municipal council passed a citizen
participation ordinance.
4.8 Short Term versus Long Term Objectives
The changing political context in Nicaragua placed severe constraints on the effectiveness of the T/AC
program.  While it is understood that USAID’s programs need to be aligned with foreign policy goals, the
assessment concludes that in this case the changes in the program were over‐determined by short term
policy considerations. This is a severe limitation for the design and implementation of effective
development programming. In particular, the decision to eliminate entirely the national level activities
with CSOs in favor of activities focused on municipal elections was damaging to USAID’s long term
development objectives.  
4.9 Perceptions of Partisan Bias
One of the points reiterated by the interviewees was the perception that the decision to shift of the
emphasis on the T/AC program to an exclusive focus on local level activities in the run‐up to the 2008
municipal elections reflected a partisan bias on the part of the USG against the FSLN.  While USAID’s
program objective was to ensure free and fair municipal elections, and required sub‐grantees to not
take a partisan stand, the decision nevertheless was seen by program counterparts and observers as
partisan in its intention. While this might have been unavoidable, given the polarized political context, it
was also predictable. It may also limit the effectiveness of future anti‐corruption programs and CSO
counterparts.  
4.10 Grant Support to NGOs
To the extent that anti‐corruption programs (and governance programs in general) incorporate
objectives related to building civil society capacities, meeting these objectives requires a long term
vision and consistent support over several years to selected organizations. Indeed, in reviewing the
experience of T/AC grantees after the program was completed, it is evident that those grantees that
received large grants over a year or more found it easier to access additional funding from other donor
agencies to maintain the activities piloted by T/AC. The grantees receiving the small grants generally did
not.
4.11 Support to CSO Coalitions
The T/AC Program was effective in supporting several coalitions of CSOs which achieved useful results in
promoting access to information legislation, pressure for IACC compliance, and building public
awareness on campaign finance and electoral reform.   While the T/AC experience shows that
partnerships and coalitions among NGOs can be effective mechanisms for channeling scarce resources
for specific goals,  these need to be built on affinity and common interest, not on monetary incentives.  
More is not always better; USAID programs should avoid cajoling CSOs and NGOs into partnerships and
coalitions.
4.12 Use of Performance Indicators
The experience of T/AC Nicaragua confirms what USAID has discovered in other programs, i.e., that an
effective governance program requires clarity on impacts and performance measures.   The difficulty on
41
the part of the contractor and USAID in defining these measures should have been a “red flag”,
indicating a lack of clarity on program objectives and strategies.  The design of the M&E plan dragged on
and once it was completed it appears to not to have been used to inform program decisions. The QPR
narratives make no mention to performance indicators.  Indeed, the program did not carry out any base
line measures (institutional assessments, surveys, etc) until the second and third years, which were not
used or disseminated.
4.13 Design of Regional Programs
Without entering into a discussion about the utility of regional programs per se, the assessment of the
T/AC Nicaragua component provides some lessons and recommendations on design criteria. Regional
programs can provide a “menu” of results, strategies and specific interventions which need to be
adjusted to country conditions and opportunities. They should aim to mobilize existing regional
resources before resorting to experts from outside the region. This will build networks and reinforce
capacities of both government institutions and civil society organizations. If there are no concrete
opportunities are identified for regional learning and capacity development, USAID might reconsider the
utility of a regional focus.
Section 5: Recommendations
  
The recommendations presented in this section follow from the analysis of main achievements
in Section 2; the problems and issues in Section 3; and the lessons identified above in Section 4.  Some
of the recommendations apply to what the program might have done better to achieve its objectives;
others apply more to future USAID/Nicaragua programming in the area of anti‐corruption, transparency
and accountability.
5. 1 Design and Procure a New Program
While they may be accused of self interest, almost all the program counterparts—and all of the former
grantees—interviewed recommended that despite the adverse political context, USAID should initiate a
new, redesigned program, focusing on strengthening transparency and accountability of government.  
They tended to emphasize CSO participation and oversight, rather than transformation of GON
institutions. The majority did not consider that there is “political space” for USAID to reach a consensus
with the incumbent FSLN government on an anti‐corruption program. The assessment concurs with this
general recommendation. It should be said, however, that most of the counterparts were extremely
critical of the design of the T/AC program. Much of the present report reflects this criticism, with
occasional caveats.
  
5.2 Critical Review of Anti‐Corruption IQCs
USAID/Nicaragua should encourage the Agency to undertake a critical review of the impact of anti‐
corruption programs funded under the previous and current IQC and consider substantial changes to its
RFP “template”.   The academic literature and available evaluation reports suggest that many of the
problems and issues identified in Section 3 are common to the other country components of the CAM
T/AC program—and to anti‐corruption programs implemented in other regions of the world.   One
important question is whether USAID funded programs have produced measurable results in hinging
support on national governments’ ability to lead “anti‐corruption plans” or in funding specialized
42
commissions. Failing a more general review, it would be useful to hold a DG workshop to explore these
issues in the LAC or CAM context.
5.3 Focus and Concentration in Design of Anti‐Corruption RFPs
Again for USAID more generally and for USAID/Nicaragua in the process of designing new anti‐
corruption RFPs.  The budget allocations for multi‐year programs in small countries such as Nicaragua
(from $1 to $2 million dollars per annum) preclude RFPs with dozens of program interventions across
multiple government entities. RFP design should focus and concentrate resources on transforming a
limited number of institutions (if the focus is on working with government counterparts) and/or
strengthening a limited number of NGOs and CSOs (if the focus is on civil society participation and
oversight).
5.4 Ensuring Commitment to Anti‐Corruption Policies and Plans
USAID/Nicaragua support for anti‐corruption programs should be predicated on verifiable GON
commitment, expressed not only in national policies, but also in strategies and plans of line ministries
and other agencies. It should be reflected in contractual terms of Task Orders, for example, a two year
T.O., with a three year option, upon meeting verifiable commitments by host governments. Related to
this, program multi‐year plans and annual work plans should be designed in conjunction with these main
government counterparts, and should incorporate policies, plans and strategies of these same
counterparts. In this same logic, the GON counterparts should be involved in annual reviews of program
performance and final evaluation.
5.5 Legislative Reforms and Change Management  
Following on the previous recommendation, USAID/Nicaragua’s future anti‐corruption programs, to the
extent that they focus on program interventions aimed at transforming public sector institutions,   
should incorporate an appropriate mix of “horizontal” reforms (i.e., legislative reforms such as access to
information laws, compliance with international conventions, public sector procurement reform, etc)
and change management interventions in individual government institutions, including interventions to
implement the legislative reforms in selected entities, thus promoting their broader implementation
throughout government.
In the event of an opposition victory in the 2011 elections, this option is politically viable, but only if it is
accompanied by the breakdown of the PLC/FSLN pact in the legislature.  Its viability should be based on
a careful, realistic assessment of the political game. If it is deemed viable, it should also be taken in
combination with recommendation 5.3 above, on the basis of clear commitment by the GON to specific
reforms, in selected line ministries and other agencies, and with a consensus on objectives, indicators
and targets.
5.6 Consider Exclusive Focus on CSOs
There is a strong possibility that Nicaragua will continue to be governed by an FSLN government, either
re‐elected in free and fair elections or through recourse to electoral fraud as in 2008. In either case,
taking the long view, USAID should consider an exclusive focus on support to CSOs in their “watchdog”
role.  The conflictive political context, coupled with the difficult relations between the USG and GON,
43
would suggest that future anti‐corruption programs not mix support to government with support to
CSOs.   
This strategy would also benefit from support for broad coalitions or alliances between CSOs.  In this
kind of program, CSOs should be free to engage the GON as they see appropriate, as opportunities
present themselves for policy debate.  This will also contribute to their long‐term political neutrality and
sustainability.  
5.7 Orient Grants to Building CSO Capacity
This recommendation is in response to the reiterated comments and suggestions of former T/AC
grantees. USAID’s support for CSOs should be oriented towards building capacities of selected CSOs and
coalitions, to enable them to exercise oversight, research and analyze policy, develop policy proposals
and promote public debate and deliberation. The support should be through multi‐year grants (two
years).  The objective should be cast in terms of sustaining civil society activism in an adverse political
environment. The program should avoid multiple, small grants to the same NGO.  This strategy does not
build capacity and places a large administrative burden on grantees.  Rather, better design of program
strategies and more careful work planning would allow for larger, medium term grants to support key
partners and build their capacity.  
5.8 Look for Sustainability in Local Government Interventions
In Nicaragua’s current political context, and taking into consideration the critical governance challenges
posed by the FSLN’s attempt to capture all government institutions, we recommend that a new anti‐
corruption program be focused on national level governance issues.  Should the decision be to include
program interventions at the local level, programs should support institutional changes, through council
resolutions and regulations referring to decision‐making processes and administrative procedures and
focus support to council members (especially opposition council members) in their implementation.  
While the T/AC supported passage of citizen participation ordinances in four municipalities, they are in
abeyance.  
A future program should explore alternative strategies, for example linkages with the elected council
members, especially opposition parties.  Alternatively, a future USAID program might want to consider
supporting partnerships between control institutions (CGR) and citizens groups in carrying out social
audits of programs and projects in the framework of formal, municipal audits. This has been tried out in
other countries. Finally, if the decision is to work at the local level, we recommend that USAID
concentrate resources in intermediate cities, rather than in small towns. The potential impact and
possibility of sustainability of interventions will be greater, owing to the greater density of civil society
organizations.  
5.9 Separate Contract Mechanisms for Electoral Activities
We recommend, too, that the grants program not include activities in support of voter registration or
promotion of voting, which under the T/AC program resulted in perceptions of political bias. The
equivalent of the small grants component of the T/AC program in 2008 should be through a different
mechanism, and be executed by different grantees, for example, those CSOs dedicated to citizen
participation in politics (Coordinadora Civica, Movimiento por Nicaragua, Movimiento Autonomo de
Mujeres, etc).   With respect to the radio programs, given the dangers of partisan bias, we recommend
44
that the support be in the form of “syndicated” programs, pre‐recorded and broadcast on the
participating radio stations.   
5.10 Better Design and Use of PMPs
Following on our discussions in Section s 3 and 4, it is evident that a future anti‐corruption program will
require careful attention to the design and use of the Performance Management Plan (PMP).  In line
with recommendation 5.3 above, we recommend that the Task Order specify that the final PMP be
designed in cooperation with the GON counterparts (if the focus is on transformation of public
institutions).   The PMP indicators and targets should reflect the plans and strategies of the GON
counterparts.  In this same logic, we recommend that the GON counterparts be involved in semi‐annual
reviews of the PMP.
5.11 Defining and Using Performance Indicators
We have underscored the importance of designing robust performance measures for anti‐corruption
programs, and the failings of T/AC Nicaragua in respect to measuring the impact on “levels of corruption
experienced by citizens”. While USAID/Nicaragua has preferred to use LAPOP oversamples for this
purpose, we recommend a technical review of this decision, in that there may be more technically
appropriate and cost‐effective methods of obtaining comparable data for performance measurement
purposes. We recommend, following the previous recommendation, that the choice of methods pay
attention to the needs of the program’s GON counterparts and to issues of sustainability.  For example,
consider using citizen score cards and other alternative methods, which can be replicated by GON
entities.
We recommend, too, that the Task Order require baseline measures of all of the key program indicators
within six months of startup, and if feasible in budgetary terms, at least a mid‐point and end‐point
measurement.
5.12 Avoid Regional Program Designs
The assessment found that the regional nature of the program caused many difficulties and delays in
decision‐making and added complexity to what is already a challenging management task. We
recommend that a future anti‐corruption program not be regional in scope; rather, when necessary and
cost‐effective draw on technical resources from other CAM countries and build on opportunities for
peer learning.    
5.13 Managing Failing Programs
Our assessment concludes that the T/AC Nicaragua program was failing by the end of Year 1, owing to
lack of GON commitment and the inability to agree on concrete strategies and interventions.  
USAID/Nicaragua should be more attuned to managing failing programs and taking prompt remedial
action. Rather than wait until mid‐2008, in hindsight USAID/Nicaragua should have cancelled the
government component of the program in 2007; there was ample evidence of lack of GON interest and
commitment. We recommend in this light and following on the other recommendations presented here,
that future USAID/Nicaragua anti‐corruption programs carry out frequent reviews (semi‐annual) with
GON counterparts and reach consensus on program continuation (or not) on the basis of verifiable
remedial actions.
45
5.14 Eliminating “Background Noise” in Grants
Finally, we recommend that USAID carry out an audit of the T/AC Nicaragua grants program, both the
“Phase 1” grants and the two rounds of small grants in “Phase 2”. In the course of our interviews, we
received many complaints about the lack of clarity in procedures, changes in contract amounts, delays in
disbursements, etc., which were not adequately explained by the contractor. This undoubtedly led to
considerable “background noise” which it would be useful to eliminate before embarking on another
program with a significant grants component—especially considering the context of a program focusing
on transparency.
  
46
Appendix A:  List of Interviewees
Haydee Acosta
Former Executive Director
Oficina de Ética Pública
Marlene Álvarez
Coordinator
RED LOCAL
Luis Aragón
Coordinator
Ética y Transparencia
Dr. Manuel Arauz
Dean,, Faculty of Legal Sciences
Universidad Centro Americana ‐UCA
Marlia Avendaño
Ex Director  
JUDENIC
Haydeé Castillo
Director
Instituto de Liderazgo
Fernando Centeno
Director
Radio Corporación
Cristiana Chamorro  
Executive Director
Fundación Violeta Barrios de Chamorro FVBCHH
Denis  Contreras
Former President
Nicaraguan Association of Internal Auditors AINN
Bernardine Dixon
Director
Ceimm‐Uraccan
Sussie Durietz  
Vice Rector
Universidad Paulo Freire, UPF
  
47
Mary Flores  
Former Coordinator
Municipal Gender Commission
Boaco
Francisco Gadea  
Director
Radio Romance
Jinotepe
Zorayda Garay
Former Technical Advisor  
Oficina Ética Pública
Claudia García  
Executive Director
IEEPP
Violeta Granera
Executive Director
Movimiento por Nicaragua
Ismael López Ocampo
Ex Program Manager  
PROBIDAD
Patricia Mayorga
Executive Director
Grupo FUNDEMOS
Denis Mayorga
Professo
r
Universidad Nacional de
Ingeniería
( UNI)
Mario Medal
Prorgam Officer
NDI
Sofia Montenegro
Executive Director
Cinco
Dr. Alberto Novoa
Ex
– Procurador
Republic of Nicaragua
  
48
Emilio Ortega
Former Technical Advisor
Oficina Ética Pública
Claudia Paniagua
Director
Fundación Nicaragua Nuestra  
Ana Quiroz
Director  
Centro de Información y Servicios de Asesoría en Salud, Cisas
María José Reyes  
Program Coordinator
ASODEL
Juan Francisco Rodríguez
Director
Fundación Rubén Darío Para el Desarrollo Humano‐ FUPADE
Enrique Saez
Deputy
Movimiento Renovador Sandinista MRS
Pedro Javier Solís
Executive Director
HAGAMOS DEMOCRACIA
Eva Tablada  
Former Mayor  
Boaco
Mignone Vega
Director
Secretary Strategic Communications (SEC)
Dr. Mauricio Zúñiga
Executive Director
IPADE
Group Interview
Carla Patricia Corea Cuadra
Fidel José Aguilar Martínez  
Darling María Solís  
Giovanni Jarquín    
Youth leaders  
IAP/ UNI Project  
Nagarote
49
Group Interview
Ulises Caldera
Mayling Obregón
Ondina Olivas
Former Technical Advisors
T/AC Nicaragua Program
  
50
Appendix B: List of Documents and Materials Consulted
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transparencia.  Mayo 31, 2007.
Besley, T. 2006. Principled Agents: The Political Economy of Good Government. Oxford: Oxford
University Press.
Booth, J.A. 1989. “Elections and Democracy in Central America: A Framework for Analysis”. In J. Booth
and M. Seligson (ed.) Elections and Democracy in Central America, Vol. 8.   Chapel Hill: The University  of
North Carolina Press.  
C&A.2006.  Respuestas  de la sociedad civil de Nicaragua al cuestionario relativo a las dispociones de la
Convención Interamericana Contra la Corrupción. Managua: C&A.
C&A. 2008.  Nicaragua Transparency and Accountability Program.  Small Grant Packet Proposal.  
Managua: C&A.
C&A. 2009.  Programa de Transparencia USAID/Nicaragua. Proyecto de Participación Ciudadana en la
Gobernanza Municipal. Informe Final. Managua: C&A.  
C& A. Manual para la participación ciudadana en el ámbito municipal.  Vols.  1‐7.  March, 2009.
EyT.2008. Sistematización de experiencias del Proyecto de Transparencia Presupuestaria. Managua: EyT.  
EyT. 2009. Una ruta hacia la Transparencia y la Gobernabilidad. Sistematización de experiencias en 25
municipios. Managua: EyT.  
EyT. 2010.  Informe de respuestas de la Sociedad Civil de Nicaragua al cuestionario de la 3ra. Ronda de
evaluación.  Managua: EyT. (http://www.eyt.org.ni/media/osc3.pdf)
Fundemos. 2007a.  Trazos de nuestra experiencia.  ¿Cómo diseñamos la campaña de comunicación en
pro de la transparencia en la política?  Managua: Grupo Fundemos.  
Fundemos. 2007b. Manual de auditoría social. Managua: Grupo Fundemos.
FUPADE. 2007.  Los procesos de auditoría social y su aporte a la gestión democrática en los municipios.  
Managua: FUPADE.    
FVBCh. 2006a. Los órganos de implementación y cumplimiento de la Ley de Acceso a la Información
Pública. Managua: FVBCh.
FVBCh. 2006b. Libertad de Información, secreto profesional y desacato. Managua: FVBCh.   
FVBCh. 2006c. La Convención Interamericana Contra la Corrupción. Managua: FVBCh.
51
Heilbrunn, J. 2004. “Anti‐Corruption Commissions Panacea or Real Medicine to Fight Corruption?”
Washington DC: World Bank Institute.
IEEP. 2007. Políticas Públicas, Participación Ciudadana y Oportunidades de Auditoria Social. Memorias
del Taller. Managua: IEEPP.  
IEEPP. 2009. Agua salada para Bluefields. Un estudio de caso sobre contrataciones públicas. With
International Budget Partnership.  Managua: IEEPP.   
IEEP. 2010. Informe de gestión del sector defensa nacional, seguridad pública y política exterior.
Managua: IEEPP.   
IEEPP. 2011a.  Marco presupuestario de mediano plazo en Nicaragua 2006‐2014. Managua: IEEPP.  
IEEP. 2011b.  PGR 2011 El gasto social en el contexto electoral y de recuperación económica.  Managua:
IEEPP.
IFES. 2006. II Conferencia Internacional de Financiamiento Político: Desafíos y Propuestas. Mangua: IFES.  
IPADE. 2007.  Manual de monitoreo sobre el financiamiento público y privado a la actividad política en
Nicaragua. Managua: IPADE.
IPADE/GPRE. 2010. Propuesta desde la Sociedad Civil: Para restaurarla confianza en el sistema electoral.
Managua: IPADE.  
Klitgaard, R. 1988.  Controlling Corruption. Berkeley: University of California Press.
Lawson, L.. 2009. “The Politics of Anti‐Corruption Reform in Africa”. Journal of Modern African  Studies
47 (1): 73‐100.
Meagher, P.  2005. “Anti‐corruption Agencies: Rhetoric versus Reality”. The Journal of Policy Reform 8
(1): 69–103.
Odd‐Helge, F. and  Isaksen, J.. 2008. “Anti‐Corruption Reforms: Challenges, Effects and Limits of World
Bank Support”. IEG Working Paper 2008/7. World Bank Independent Evaluation Group.
Persson, A., Rothstein, B. and Teorell, J. 2010. “The failure of Anti‐Corruption Policies: A Theoretical Mis‐
characterization of the Problem”.   QoG Working Paper Series 2010: 19. The Quality of Government
Institute. Department of Political Science, University of Gothenburg.
Programa Fondo Conjunto de Donantes para la Anticorrupción. 2009.  Diagnostico de la corrupción en
Nicaragua.  Managua.  
Prud’homme, R. 1995. “On the Dangers of Decentralization,” World Bank Research Observer, 10, 2,
pp.201‐209
52
Red Probidad. 2007a.  Investigación de Casos de corrupción: ¿Dónde estamos y hacia dónde vamos?.
Managua: PROBIDAD.
Red Probidad. 2007b. Iniciativas de aprendizaje y oportunidades para Nicaragua.  
Rose‐Ackerman, S.  1978. Corruption. A Study in Political Economy. London/New York: Academic Press.
Shah, A. 2006. “Corruption and Decentralized Public Governance”. World Bank Policy Research Working
Paper No. 3824.  
Shah, A.   2007. “Tailoring the Fight against Corruption to Country Circumstances”. In Performance
Accountability and Combating Corruption, Edited by Anwar Shah, 233–254. Washington D.C.: World
Bank.